Private fund managers are reminded that the Corporate Transparency Act (CTA) may trigger reporting obligations to the Department of the Treasury’s Financial Crimes Enforcement Network for private fund managers and the private funds they manage in 2024 as soon as 90 days after the initial organization of a new entity or by January 1, 2025, for existing entities (formed prior to January 1, 2024). Private fund managers should now be conducting an entity-by-entity analysis of each entity within their structures to confirm whether such entity is a reporting company under the CTA. In particular, SEC exempt reporting advisers relying on the private fund adviser exemption, state-only exempt reporting advisers, state registered investment advisers and foreign investment advisers registered to do business in the U.S. may be within scope of the CTA and should carefully review their reporting obligations under the CTA requirements.