Corporate Transparency Act Update – Extension of Filing Deadline for Reporting Companies Registered in 2024; Small Entity Compliance Guide

FinCEN Proposes Rule Extending Initial Filing Deadline for CTA Reporting Companies Created or Registered in 2024

On September 28, 2023, the US Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) published a Notice of Proposed Rulemaking (NPRM) regarding the Corporate Transparency Act (CTA). The NPRM proposed to extend the deadline for reporting companies created or registered in 2024 to file their initial beneficial ownership information (BOI) under the Corporate Transparency Act (CTA) (effective January 1, 2024) from 30 days to 90 days; the NPRM makes no other proposed changes.

Under the NPRM, FinCEN clarifies that the proposed extension is only for entities created this introductory year as filers get used to the CTA and, as proposed, will not apply to the initial BOI filings of reporting companies formed or registered before January 1, 2024, or on or after January 1, 2025. Comments on the NPRM must be submitted to FinCEN by October 30, 2023.

FinCEN Publishes Small Entity Compliance Guide Ahead

On September 18, 2023, FinCEN issued a press release announcing the publication of its Small Entity Compliance Guide to assist the small business community prepare for compliance with the BOI requirements under the CTA (effective January 1, 2024). The guide:

  • Describes the BOI reporting rule's provisions;
  • Answers key questions; and
  • Provides checklists and other tools to assist businesses in complying with the CTA.

The press release also notes that FinCEN will release additional guidance on submitting BOI soon.


For more on the CTA and upcoming compliance requirements, see our previous post here. If you have any questions about the issues addressed in this article, or if you would like a copy of any of the materials mentioned in it, please do not hesitate to reach out to:

Patrick Ellis
Kuhn Rogers PLC
Phone: +1 231-947-7900

Categories: Legal Insights