10/4/2024

ALERT – THE CORPORATE TRANSPARENCY ACT (CTA) – AN UPDATE

Referencing our alert, The Corporate Transparency Act (CTA): What Your Business Needs to Know for 2024 – Dilworth Paxson LLP, the Financial Crimes Enforcement Network (FinCEN) has announced that it has updated its Frequently Asked Questions in the following areas:

A. General Questions

  • Access to BOI (A3 and A6)

B. Reporting Process

  • Who Can File a BOI Report (B7 and B8)
  • Unauthorized Practice of Law (B9)
  • How to Report Multiple Beneficial Owners and Company Applicants (B10)

C. Reporting Company

  • What Are Considered Similar Offices (C17)
  • Corporate Conversion (C18)
  • Registering in Multiple States (C19)

D. Beneficial Owner

  • Number of Beneficial Owners (D1i)
  • No Beneficial Owners with Ownership Interest (D1ii)
  • Community Property (D18)

F. Reporting Requirements

  • Acceptable Identification Documents (F5i, F5ii, F15)
  • Reporting Company Address (F12)
  • Address Confidentiality Programs (F14)

L. Reporting Company Exemptions

  • Subsidiary Exemption (L3i, L6)
  • PIV Exemption (L10)
  • Operating from a Personal Residence (L11)

M. FinCEN Identifier

  • FinCEN Identifier Use and Updates (M2 and M5i)

N. Third-Party Service Providers

  • Third-Party Service Providers (N4)

The entire set of FAQs can be accessed at https://www.fincen.gov/boi-faqs

We are poised to assist with your reporting compliance, to determine if a statutory exemption is available for your business and to respond to other CTA-related questions. Please contact your Dilworth attorney or Graham R. Laub, Rosemary J. Loverdi, Roger F. Wood, or Andrea N. Metz of Dilworth Paxson LLP’s Corporate and Business practice.