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.