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FinCEN Clarifies that Dissolved Entities are Subject to CTA Reporting Obligations

On July 8, 2024, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) released additional FAQs with respect to the beneficial ownership reporting requirements of dissolved entities. The Corporate...more

U.S. District Court in Alabama Finds the Corporate Transparency Act Unconstitutional

On March 1, 2024, Judge Liles C. Burke of the U.S. District Court for the Northern District of Alabama ruled that the Corporate Transparency Act (the “CTA”) is unconstitutional, leaving its future uncertain. The CTA requires...more

The Corporate Transparency Act: Key Considerations for Health Systems and Practice Management Companies (MSOs/DSOs)

In 2021, Congress enacted the Corporate Transparency Act (the “CTA”) to “better enable critical national security, intelligence, and law enforcement efforts to counter money laundering, the financing of terrorism, and other...more

CTA: FinCEN Clarifies Ownership Interests Must be Entirely Controlled or Wholly Owned to Qualify for the Subsidiary Exemption

On January 12, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) released additional FAQs in response to questions received regarding compliance with various aspects of the Corporate...more

CTA – Accessing Beneficial Ownership Information

On December 21, 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued the final rule on Beneficial Ownership Information Access and Safeguards (the “Access Rule”) laying out the...more

CTA – The Large Operating Company Exemption – Not Everybody Can Be A “Big BOI”

In 2021, the Corporate Transparency Act (the “CTA”) was enacted into U.S. federal law as part of a multi‑national effort to rein in the use of entities to mask illegal activity. The CTA directs the U.S. Department of the...more

U.S. FinCEN Extends Timeframe for Reporting Companies Created in 2024 to File Beneficial Ownership Information Reports

Today, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued a final rule aimed to ease compliance with certain aspects of the regulations promulgated under the Corporate Transparency Act. The...more

Countdown to Transparency: Beneficial Ownership Reporting

In 2021, the U.S. enacted the Corporate Transparency Act (the “CTA”) as part of a multi‑national effort to rein in the use of entities to mask illegal activity. The CTA directs the U.S. Department of the Treasury’s Financial...more

Paycheck Protection Program – SBA Clarifies PPP Guidance

Third-Party Payroll Providers Cleared - On June 13, 2023, the U.S. Small Business Administration (“SBA”) issued new FAQ 72 (“FAQ 72”) to help clarify whether amounts paid by borrowers to third-party payers for the...more

Shining a Light on the Corporate Transparency Act: FinCEN’s Rules for Beneficial Ownership Reporting

On January 1, 2021, Congress enacted the Corporate Transparency Act (the “CTA”) as part of the Anti-Money Laundering Act of 2020 in the National Defense Authorization Act for Fiscal Year 2021. Congress passed the CTA to...more

Front and Center: Latest SVO Grant Numbers (UPDATED)

The SBA stopped accepting new SVO Grant applications on August 20, 2021.  The SBA is currently reviewing submitted SVO Grant applications and issuing both initial and supplemental awards. As of December 13, 2021, the SBA had...more

Front and Center: Latest SVO Grant Numbers (UPDATED)

The SBA stopped accepting new SVO Grant applications on August 20, 2021.  The SBA is currently reviewing submitted SVO Grant applications and issuing both initial and supplemental awards.  As of November 29, 2021, the SBA had...more

Front and Center: Latest SVO Grant Numbers (UPDATED)

The SBA stopped accepting new SVO Grant applications on August 20, 2021.  The SBA is currently reviewing submitted SVO Grant applications and issuing both initial and supplemental awards. As of November 15, 2021, the SBA had...more

Front and Center: Latest SVO Grant Numbers (UPDATED)

The SBA stopped accepting new SVO Grant applications on August 20, 2021. The SBA is currently reviewing submitted SVO Grant applications and issuing both initial and supplemental awards. As of November 8, 2021, the SBA had...more

Front and Center: Latest SVO Grant Numbers - (UPDATED)

The SBA stopped accepting new SVO Grant applications on August 20, 2021. The SBA is currently reviewing submitted SVO Grant applications and issuing both initial and supplemental awards. As of October 25, 2021, the SBA had...more

Front and Center: Latest SVO Grant Numbers (UPDATED)

The SBA stopped accepting new SVO Grant applications on August 20, 2021.  The SBA is currently reviewing submitted SVO Grant applications and issuing both initial and supplemental awards. As of October 12, 2021, the SBA had...more

Front and Center: Latest SVO Grant Numbers (UPDATED)

The SBA stopped accepting new SVO Grant applications on August 20, 2021.  The SBA is currently reviewing submitted SVO Grant applications and issuing both initial and supplemental awards.  As of October 4, 2021, the SBA had...more

Where Are We Now? An Up-to-Date Guide to the Paycheck Protection Program

Since the enactment of the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”) on March 27, 2020, Congress has enacted subsequent laws and the U.S. Small Business Administration (the “SBA”) and the U.S...more

Paycheck Protection Program – Borrower Appeals of Final SBA Loan Review Decisions

On September 16, 2021, the U.S. Small Business Administration (“SBA”) issued an Interim Final Rule (the “Borrower Appeal Rule”) detailing the (largely technical) procedures for a Paycheck Protection Program (“PPP”) borrower...more

Front and Center: Latest SVO Grant Numbers (UPDATED)

The SBA stopped accepting new SVO Grant applications on August 20, 2021. The SBA is currently reviewing submitted SVO Grant applications and issuing awards. As of September 20, 2021, the SBA had made decisions on 95% of all...more

Front and Center: Latest SVO Grant Numbers (UPDATED)

The SBA stopped accepting new SVO Grant applications on August 20, 2021. The SBA is currently reviewing submitted SVO Grant applications and issuing awards. As of September 13, 2021, the SBA had made decisions on 94% of all...more

SBA Expands COVID Disaster Loans

Effective September 8, 2021, the U.S. Small Business Administration (“SBA”) significantly expanded the ability of small businesses to apply for low-interest loans through the revised COVID Economic Injury Disaster Loan...more

Front and Center: Latest SVO Grant Numbers (UPDATED)

The SBA stopped accepting new SVO Grant applications on August 20, 2021. The SBA is currently reviewing submitted SVO Grant applications and issuing awards. As of September 7, 2021, the SBA had made decisions on 93% of all...more

Front and Center: Latest SVO Grant Numbers (UPDATED)

The SBA stopped accepting new SVO Grant applications on August 20, 2021. The SBA is currently reviewing submitted SVO Grant applications and issuing awards. As of August 30, 2021, the SBA had made decisions on 90% of all...more

Front and Center: Latest SVO Grant Numbers (UPDATED)

The SBA is currently reviewing SVO Grant applications and issuing awards. As of August 17, 2021, the SBA had made decisions on 97% of all applications. SVO Grant program reports, which detail the number of applications...more

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