The Corporate Transparency Act – Partial Delay

The Federal Government passed the Corporate Transparency Act with bipartisan support in 2021. The reporting requirements under the Corporate Transparency Act (the “Act”) go into effect on January 1, 2024. There has been much discussion and commentary that the federal government will delay the date that companies will need to begin complying with the terms of the Act. While FinCen proposed a delay on September 27, 2023, this is not the delay that people were expecting/hoping for.

I think it will be helpful to provide a bit of background as timing of reporting requirements which were part of the original rule. For companies that were created on or before December 31, 2023, these companies will have until December 31, 2024 to submit the mandatory reporting information with FinCen. For companies that were created on or after January 1, 2024, these companies were to have thirty days to submit the mandatory reporting information with FinCen.

On September 27, 2023, FinCen initiated a request for a change to the mandatory reporting deadline; however, the change being requested is that companies created between January 1, 2024 and December 31, 2024 have ninety days to file the mandatory reporting information with FinCen instead of the originally planned thirty days. The requested rule change DOES NOT change that companies created prior to December 31, 2023 have until December 31, 2024 to submit the mandatory reporting information with FinCen and companies created after January 1, 2025 have the original thirty days to comply and submit the mandatory reporting information with FinCen.

On November 30, 2024, the proposed reporting change is now a final rule. Companies created between January 1, 2024 and December 31, 2024 now have ninety days to file the mandatory report with FinCen. Companies created on or after January 1, 2025 have the original thirty days to file the mandatory report with FinCen. So, the essence of this change is that a company created in 2024 will have ninety days instead of thirty days to submit the mandatory reporting information with FinCen.

Please look for additional articles to be published on the topic of the Corporate Transparency Act. If you have any questions regarding the Corporate Transparency Act or if you will need assistance in complying with the filing requirements, do not hesitate to be in contact.

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Chris Corpus

Founding Partner at Corpus Law Inc

This article does not provide legal advice or create an attorney-client relationship. If you have any questions or would like to learn more about this topic or if you have other legal questions, do not hesitate to contact Chris Corpus, Esq. of Corpus Law Inc at 216-973-2475. Copyright Christopher A. Corpus 2024.