On November 29, FinCEN extended from 30 to 90 days the deadline for reporting companies created or registered on or after January 1, 2024, to file their initial beneficial ownership information (BOI) reports under the Corporate Transparency Act. The deadlines for other reporting companies remain unchanged. See FinCEN’s release; these posts from Proskauer and McGuire Woods; and our prior report: “Ready or Not: Here Comes the Corporate Transparency Act.”
In addition, on November 16, FinCEN published updated FAQs on the BOI Reporting Rule. New questions encompass the reporting process, reporting companies, beneficial owners, company applicants, reporting requirements, initial reports, and reporting company exemptions. FinCEN’s main BOI webpage also houses a “Contact FinCEN” button to accommodate beneficial ownership inquiries through an online portal.
The updated FAQs follow FinCEN’s issuance of a final rule on November 7 that specify when and how a reporting company may use a FinCEN identifier to report beneficial ownership information.