FinCEN Reporting Requirements | Corporate Transparency Act

8.4.24

As we previously reported, the recently enacted Corporate Transparency Act requires nearly all US business entities to file a report with the federal government. There are a number of exceptions (e.g., large operating companies-$5M in revenue, 20 employees, and members who own less than a 25% interest in the company - see Small Entity Compliance Guide, p.2). However, for the most part, the rule broadly requires most entities to report.

For entities in existence before January 1, 2024, the filing deadline is January 1, 2025. (For entities that are formed after January 1, 2024, the filing deadline is 90 days after formation, and we take care of this for entities that are newly formed by us.)

This is something you may be able to handle yourself (see www.fincen.gov/boi) or we can assist you.  If we file for you, our fee will be $300 per entity.

To be considered "ready" for Financial Crimes Enforcement Network (“FinCEN”) reporting requirements, all beneficial owners and controlling persons1 (see Beneficial Ownership Information Reporting Rule Fact Sheet must submit government IDs (passport or driver’s license). If you would like us to file this report for you, then you should proceed as follows:

1.  Contact our office via email to Suzy Henline to let us know this is something you would like us to handle for you. In your email, include:

  • Name of each entity.
  • Name of each beneficial owner/controlling person.

2.  We will send you the secure link to upload your government ID; if a driver’s license, please scan and send both the front and back of the card, and if a passport, please scan and send the page containing your photo and personal information (full name, nationality, date of birth, place of birth, passport issue date and passport expiration date).

3.  Upon receipt thereof, we will file the report for you and provide you with the filing confirmation.

If questions remain, please contact Suzy Henline at Schwartz Semerdjian.

1 These terms includes any individual who, directly or indirectly, either (1) exercises substantial control over a reporting company, or (2) owns or controls at least 25 percent of the ownership interests of a reporting company.  If in doubt, probably best to report.