On March 21, 2025, FinCEN published an “interim final rule” (IFR) that makes sweeping changes in the reach of the Corporate Transparency Act. The IFR is immediately effective and eliminates all BOI report obligations for all...more
On March 2, 2025 the U.S. Treasury Department laid waste to about a million law firm postings about the Corporate Transparency Act, announcing that Treasury now intends to propose fundamental changes to the CTA Rule and that...more
On February 27, 2025, FinCEN issued a press release announcing future changes but giving no guidance about the scope of those changes:
“No later than March 21, 2025, FinCEN intends to issue an interim final rule that...more
Updated February 20, 2025.
The CTA seesaw continues. On February 19, FinCEN announced it is reinstating the CTA reporting obligations and setting new deadlines for submissions. Says FinCEN:
“For the vast majority of...more
FinCEN announced on January 24:
In light of a recent federal court order, reporting companies are not currently required to file beneficial ownership information with FinCEN and are not subject to liability if they fail to...more
1/27/2025
/ Anti-Money Laundering ,
Appeals ,
Beneficial Owner ,
Constitutional Challenges ,
Corporate Transparency Act ,
Enforcement Actions ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reporting Requirements
On December 3, 2024, a US District Court in Texas ruled the Corporate Transparency Act unconstitutional and issued a nationwide preliminary injunction against its enforcement. That ruling was promptly appealed, and on...more
12/27/2024
/ Appeals ,
Beneficial Owner ,
Business Entities ,
Business Ownership ,
Corporate Transparency Act ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements ,
Smaller Reporting Companies ,
Stays ,
Time Extensions
You perhaps have heard the news that a US District Court in Texas ruled the Corporate Transparency Act unconstitutional and issued a nationwide preliminary injunction against its enforcement. In all, four US District Courts...more
In June we circulated an article entitled “Mid-year assessment: Are you in good shape on CTA compliance?” The Corporate Transparency Act (CTA) deadline for filing BOI reports with FinCEN is now less than three months away –...more
Yesterday afternoon (August 20, 2024), the United States District Court for the Northern District of Texas blocked the Federal Trade Commission’s (FTC) Final Rule banning most non-competition agreements between employers and...more
8/21/2024
/ Employees ,
Employer Liability Issues ,
Employment Contract ,
Federal Bans ,
Federal Trade Commission (FTC) ,
Final Rules ,
FTC Act ,
Non-Compete Agreements ,
Popular ,
Set-Asides ,
Statutory Authority
The Corporate Transparency Act (CTA) will require most privately-owned entities to file Beneficial Ownership Information (BOI) reports with FinCEN no later than January 1, 2025. The purpose of this Client Alert is to check in...more
7/2/2024
/ Beneficial Owner ,
Business Ownership ,
Compliance ,
Corporate Transparency Act ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Noncompliance ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements
Recent Development -
On March 1, 2024, a federal court in Alabama ruled that the Corporate Transparency Act violates the U.S. Constitution and is unenforceable on its face. The decision (NSBU v. Yellen) is highly...more
The Corporate Transparency Act became effective January 1, 2024 and will require more than 30 million U.S. entities to register in 2024 with FinCEN (a bureau of the U.S. Treasury Department). Most large companies and...more
2/15/2024
/ Beneficial Owner ,
Business Entities ,
Business Ownership ,
Corporate Transparency Act ,
Enforcement ,
Exemptions ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Noncompliance ,
Penalties ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements ,
Smaller Reporting Companies
This is an update to the August 18, 2023 article published on the Maine Venture Fund's website. The article on this site was orginally published on November 27, 2023 and has been updated since the CTA Reporting Regime went...more
The article was orginially posted on November 28, 2023 and has been updated to reflect changes that took effect in 2024.
During 2024 the Corporate Transparency Act (CTA) and related CTA Rule will require an estimated 32.6...more
This article was originally posted on November 30, 2023 and has been updated to reflect changes that went into effect in 2024.
The Corporate Transparency Act (CTA) took effect on January 1, 2024. The Act is administered by...more
1/30/2024
/ Beneficial Owner ,
Business Entities ,
Corporate Transparency Act ,
Filing Deadlines ,
Financial Regulatory Reform ,
FinCEN ,
Publicly-Traded Companies ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements ,
Shell Corporations
The article was originally posted on November 29, 2023 and has been updated to reflect changes that went into effect in 2024.
Under the Corporate Transparency Act (CTA), more than 30 million “Reporting Companies” will...more
1/30/2024
/ Beneficial Owner ,
Business Entities ,
Corporate Transparency Act ,
Filing Deadlines ,
Financial Regulatory Reform ,
FinCEN ,
Publicly-Traded Companies ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements ,
Shell Corporations
The Corporate Transparency Act (CTA) takes effect starting January 1, 2024. The Act is administered by FinCEN, a bureau of U.S. Treasury charged with combatting money laundering and other financial crimes. The central feature...more
Under the Corporate Transparency Act (CTA), more than 30 million “Reporting Companies” will need to register with FinCEN (a bureau of the U.S. Treasury Department) and file Beneficial Ownership Information (BOI) reports...more
In 2024 the Corporate Transparency Act (CTA) and related CTA Rule will require more than 30 million “Reporting Companies” to register with FinCEN, a bureau of U.S. Treasury. Registration occurs through online filings of...more
11/30/2023
/ Beneficial Owner ,
Business Entities ,
Business Ownership ,
Corporate Governance ,
Corporate Transparency Act ,
FinCEN ,
Policies and Procedures ,
Registered Investment Advisors ,
Regulatory Requirements ,
Reporting Requirements ,
Securities and Exchange Commission (SEC)
Presently, forming a corporation, LLC or other entity in the U.S. can be done on a largely anonymous basis, without naming its owners and with only limited disclosures about managers, officers and directors. Under the...more
11/2/2023
/ Beneficial Owner ,
Business Entities ,
Corporate Governance ,
Corporate Transparency Act ,
Doing Business ,
Filing Deadlines ,
Financial Regulatory Reform ,
FinCEN ,
Publicly-Traded Companies ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements ,
Shell Corporations
Presently, forming a corporation, LLC, or other entity in the U.S. can be done on a largely anonymous basis, without naming its owners and with only limited disclosures about managers, officers, and directors. Under the...more
9/20/2023
/ Anti-Money Laundering ,
Beneficial Owner ,
Business Entities ,
Corporate Transparency Act ,
Doing Business ,
Financial Crimes ,
Financial Regulatory Reform ,
FinCEN ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements
Most private companies in the United States will soon need to disclose sensitive ownership and control information to FinCEN, a bureau of the U.S. Treasury Department. The new reporting regime arises under the Corporate...more
How to use this article: You already know that the Paycheck Protection Program (PPP) is highly complex, with intertwining conditions, exceptions, and definitions that defy simple explanation. This article assumes that you are...more
Originally enacted on March 27, the Paycheck Protection Program (PPP) offers loan support and (potentially) loan forgiveness to qualifying small businesses – generally defined as those with not more than 500 employees....more
On June 11, the Small Business Administration (SBA) and the Treasury Department published important guidance that the revised 60% condition under the Paycheck Protection Program Flexibility Act will be applied...more