In 2023, SSEG told you about the Corporate Transparency Act, which went into effect on January 1, 2024. This is a reminder that small businesses must file a Beneficial Ownership Report, and the deadline for this report is approaching.

Your deadline depends on when your company was formed. If you formed your company:

• before January 1, 2024, then you must file your initial report before January 1, 2025.
• on or between January 1, 2024 and December 31, 2024, then you must file your initial report within 90 days of forming the company.
• on or after January 1, 2025, then you must file your initial report within 30 days of forming the company.

If there are any changes to your company’s ownership, then these changes must be filed with FinCEN within 30 days.

Since the law took effected, there have been lawsuits challenging the beneficial ownership reporting requirements. As a result of one lawsuit, FinCEN is not enforcing the beneficial ownership requirements against members of the National Small Business Association. While lawsuits remain ongoing, FinCEN is requiring all other reporting companies to file.

For more information about filing your beneficial ownership report, contact any member of the SSEG Business Law, Transactional Law, Securities Law, and Corporate Law practice group.