UPDATE: On March 21, 2025, the Financial Crimes Enforcement Network issued an Interim Final Rule removing Beneficial Ownership Information Reporting requirements for U.S. companies and U.S. individuals under the Corporate Transparency Act. For more details, please view our latest alert here.

On January 1, 2021, Congress enacted the Corporate Transparency Act (the “CTA”), which requires certain companies disclose the identity of their owners to the Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) through the filing of Beneficial Ownership Information Reports (“BOIRs”). For a quick overview, you can read about the basics of the Act and what you need to know about its implementation here.

All entities in existence on January 1, 2024, and which qualify as a reporting company, are required to file a BOIR on or before January 1, 2025. The initial BOIR filing due on or before January 1, 2025 is required even if the reporting company has or will be dissolved prior to the January 1, 2025 deadline, so long as the entity was in existence on January 1, 2024.

Reporting companies formed during the 2024 calendar year must file their BOIRs within 90 days of their formation. Any entity formed on or after January 1, 2025 which is classified as a reporting company must file their BOIRs within 30 days of their formation.

The attorneys at Barley Snyder continue to follow the Corporate Transparency Act closely and provide updates as new information is released. If you have any questions regarding the CTA, the beneficial ownership disclosure requirements, or would like assistance in the preparation or filing of you BOIR, please contact Dan Desmond, Charmaine Nyman, Elizabeth Vanasse or any member of Barley Snyder’s Business Practice Group. You may also visit our Corporate Transparency Act Response Team webpage for more information and additional alerts on this matter.