Overview

During this event, we will discuss the Corporate Transparency Act (“CTA”) and its implementing rules which mandate that Reporting Companies, such as corporations, limited liability companies or similar types of entities, provide beneficial ownership information (“BOI”) to FinCEN upon formation, similar to what financial institutions are currently required to obtain under FinCEN’s 2016 beneficial ownership rule (commonly referred to as the CDD Rule).

To implement the CTA, FinCEN is directed to engage in three rulemakings.  On September 30, 2022, FinCEN issued its first final rule which sets out the requirements for Reporting Companies to follow when reporting BOI to FinCEN.  Subsequently, on December 21, 2023, FinCEN issued the second final rule that sets out the circumstances under which BOI reported to FinCEN may be accessed by federal agencies; state, local, Tribal, and foreign governments; and financial institutions.

The final required rulemaking is expected to be essentially a complete overhaul of the CDD Rule, as mandated by the CTA, but is not anticipated to be issued until later in 2024.

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