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 […]
Tag: Beneficial Ownership
FinCEN Ruling on Identifiers in Beneficial Ownership Reporting
Earlier this week on November 7, 2023, FinCEN issued a Final Rule on the use of FinCEN identifiers in Beneficial Ownership information reporting after commenters raised concerns that the previously proposed language could actually obscure the identities of beneficial owners. The Final Rule provides clear criteria on the use and reporting of an entity’s FinCEN identifier. What is a FinCEN identifier? A “FinCEN identifier” is a unique identifying number that FinCEN will issue to an […]
FINCEN PROPOSES BENEFICIAL OWNERSHIP INFORMATION
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 […]
FINCEN ISSUES ANPRM ON BENEFICIAL OWNERSHIP REPORTING
On April 1, 2021, FinCEN issued an Advance Notice of Proposed Rulemaking (ANPRM) requesting comments on new beneficial ownership reporting provisions included in the Corporate Transparency Act/Anti-Money Laundering Act of 2020, which was passed into law as part of the National Defense Authorization Act of 2021 on January 1, 2021. The ANPRM, published in the Federal Register on April 5, 2021, is requesting input on procedures and standards for reporting companies to submit information to […]
FinCEN PROVIDES RELIEF FROM BENEFICIAL OWNERSHIP RULES FOR ROLLOVERS AND RENEWALS
On Friday, September 7, 2018, the Financial Crimes Enforcement Network (FinCEN) issued a ruling which grants certain exceptions for financial institutions from the Beneficial Ownership Rule. Specifically the ruling provides financial institutions relief from the obligations under the Beneficial Ownership Requirements of identifying Legal Entity Customers in the case of: •A rollover of a certificate of deposit (CD) •A renewal, modification, or extension of a loan (e.g., setting a later payoff date) that does not […]