Latest Update to Beneficial Ownership Reporting

As you’re probably already aware, FinCEN issued the Beneficial Ownership Information Access and Safeguards Rule (Access Rule) on December 22, 2023. This rule implements portions of the Corporate Transparency Act (CTA) and authorizes certain persons access to information reported to FinCEN regarding reporting companies, beneficial owners, and company applicants (BOI). On February 20, 2024, the effective date of the Access Rule, FinCEN published a Small Entity Compliance Guide for Beneficial Ownership Information Access and Safeguards […]

Beneficial Ownership Filing Deadline Extension from FinCEN

Yesterday, FinCEN announced a filing deadline extension for Beneficial Ownership Information for companies created or registered in 2024. Beginning January 1, 2024, reporting companies will be required to file information with FinCEN regarding their beneficial ownership. The rule requires new reporting companies, that is those created after January 1, 2024, to file their initial report within 30 calendar days of “receiving actual or public notice that the creation or registration of the reporting company is […]


On December 8, 2021, the Financial Crimes Enforcement Network (FinCEN) proposed regulations to require certain entities to file reports with FinCEN that identify two categories of individuals: The beneficial owners of the entity; and Individuals who have filed an application with specified governmental authorities to form the entity or register it to do business. The proposed regulations would implement Section 6403 of the Corporate Transparency Act (CTA), enacted into law as part of the National […]

BSA Modifications Included in National Defense Authorization Act

On January 2, 2021, the United States Congress enacted the National Defense Authorization Act for 2021 (H.R. 6395) (NDAA of 2021 or the Act), which passed both the House of Representatives and Senate in early December but was vetoed by the President in late December, by voting to override the President’s veto on the legislation. The NDAA of 2021 includes banking industry backed provisions to modernize, enhance, and reform anti-money laundering processes as outlined in […]


The Small Business Administration’s Paycheck Protection Program, authorized by the CARES Act, became available on April 3 for small businesses and sole proprietorships and on April 10 for independent contractors and self-employed individuals. Lenders participating in the PPP have been overwhelmed by the number of applicants and are working diligently to process the loans expeditiously. One concern for lenders is providing a quick turnaround while still complying with the Bank Secrecy Act requirements. The SBA […]