Corporate Transparency Act Update

Corporate Transparency Act Update
We want to bring to your attention an important development in corporate compliance – the Corporate Transparency Act (CTA).

Effective January 1, 2024, all U.S. and foreign companies that were formed in or have registered with any of the 50 U.S. states must comply with new Beneficial Ownership Information (BOI) reporting requirements from the Financial Crimes Enforcement Network (FinCEN), as prescribed by the CTA. More information may be found on the official FinCEN government website.
We are pleased to announce that RS&F has teamed up with CTA Filing Center ( to ensure seamless filing and reporting of BOI information. We believe a partnership with a best-in-class technology and security portal is best for you as we navigate through these new reporting requirements. Benefits of using the CTA Filing Center platform include:

  • Consolidates all entities registered by BOI reporting filers
  • Maintains previously submitted information to support future filing updates
  • Facilitates BOI record collection by parties responsible for filing a BOI form
About Beneficial Ownership Information Reports

Who must file?

Most corporations, LLCs, and limited partnerships will likely need to file a BOI report, but some businesses are exempt. Click here to complete a questionnaire to determine if your company is required to file.

Who is a beneficial owner?
– Anyone who possesses or exercises control over twenty-five percent or more of the voting stock or equivalent of the company is considered a beneficial owner.

– Any individual who, directly or indirectly, can exercise substantial influence over the reporting firm is considered a “beneficial owner.” Chief Executive Officer, President, and General Counsel are all examples of such high-ranking personnel.

What is a FinCEN ID?
– A FinCEN ID is a unique identifying number issued to an individual by FinCEN. Although there is no requirement to obtain a FinCEN ID, doing so can simplify the reporting process. To obtain a FinCEN ID, go to the FinCEN ID website.

– An individual beneficial owner or company applicant’s FinCEN ID can be reported instead of required information about that individual on the reporting company’s Beneficial Ownership Information Report (BOIR) submitted to FinCEN.

When is the deadline?
– If a company was formed with an effective date before January 1, 2024, then the initial report is due no later than January 1, 2025.

– If a company is created with an effective date on or after January 1, 2024, then the initial report is due within 90 days of the date the entity is created.

What are the penalties?
– The potential penalties for this violation can be severe, including a daily fine of $500 for each day the issue remains unresolved, up to a maximum of $10,000.
– There’s a possibility of criminal penalties that may include imprisonment for up to 2 years.

If you have any questions regarding the CTA Filing Center or new BOI reporting requirements, please contact RS&F’s Back Office Services Manager, Anthony DiMartino.
If you have specific questions regarding whether you have to file a BOI form and/or who qualifies as a beneficial owner, please contact your counsel (or we can recommend an attorney, upon request).
We appreciate your business and look forward to assisting you in navigating these important new requirements.