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Practical Implications of the Interim Final Rule for BOI Reporting Under the CTA

As we previously discussed, the Financial Crimes Enforcement Network (FinCEN) published an interim final rule (IFR) on March 26 that narrowed the beneficial ownership information (BOI) reporting requirements under the...more

CTA Significantly Amended by Interim Final Rule

On March 21, the Financial Crimes Enforcement Network (FinCEN) submitted an interim final rule (IFR) to the Federal Register, regarding the beneficial ownership information (BOI) reporting requirements under the Corporate...more

Summary Overview: 3 Steps to CTA Compliance

The January 1, 2025, compliance deadline for Corporate Transparency Act (CTA) filings for certain entities that were formed or registered to do business in the U.S. before 2024 is approaching quickly for many business owners....more

Upcoming Corporate Transparency Act Compliance Deadlines

As we are now in the fourth quarter of 2024, it is crucial for business owners to focus on the upcoming Corporate Transparency Act (CTA) reporting deadlines and to take the necessary steps to ensure compliance. The CTA is...more

FinCEN Publishes Updated FAQs Regarding CTA Filings for Dissolved Entities and Withdrawn Foreign Entities

On September 10, the Financial Crimes Enforcement Network (FinCEN) published updated guidance in the form of new and revised frequently asked questions (FAQs), C.14-C.16 and G.4, regarding beneficial ownership information...more

FinCEN Clarifies CTA Reporting Requirements for Entities That No Longer Exist

On July 8, the Financial Crimes Enforcement Network (FinCEN) published three new Frequently Asked Questions (FAQ), C.12 - C.14, that address beneficial ownership information (BOI) reporting requirements under the Corporate...more

FinCEN Issues Final Rule on Use of Entity FinCEN Identifiers to Fulfill BOI Reporting Requirements Under the CTA

Brief Overview: On November 8, the Financial Crimes Enforcement Network (FinCEN) published a final rule specifying the circumstances under which a reporting company may report another entity’s FinCEN identifier in lieu...more

Notable Requirements Under FinCEN's Final Rule Implementing the Corporate Transparency Act Reporting Framework

The Financial Crimes Enforcement Network (FinCEN) has published a final rule, implementing Section 6403 of the Corporate Transparency Act (CTA), with sweeping beneficial owner and company applicant reporting requirements that...more

SEC Proposes Amendments to Certain Bases to Exclude Shareholder Proposals Under Rule 14a-8

On July 13, the Securities and Exchange Commission (SEC) released a proposed rule that would amend 17 CFR 240.14a-8 (Rule 14a-8) to revise three of the bases for excluding shareholder proposals from a company’s proxy...more

Comptroller of the Currency Cites TBTF Risks at Large Regional Banks

On April 1, Acting Comptroller of the Currency Michael J. Hsu stated that the OCC, under the “significant role” it plays in national bank mergers, is considering certain “resolvability safeguards” with its review of larger...more

CBA Requests Increased CFPB Supervision of Fintechs Via the Larger Participant Rule

The Consumer Bankers Association (CBA), a trade group of retail financial institutions, recently sent a letter to the Consumer Financial Protection Bureau (CFPB) director, requesting increased supervision of financial...more

The Federal Reserve, FDIC, and OCC Publish Proposed Interagency Guidance on Third-Party Relationships: Risk Management

The Board of Governors of the Federal Reserve System (Board), the Federal Deposit Insurance Corporation (FDIC), and the Department of the Treasury Office of the Comptroller of the Currency (OCC) have published proposed...more

7/30/2021  /  Banking Sector , Banks , FDIC , OCC
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