Corporate Transparency Act – Dealer Compliance Alert

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The Corporate Transparency Act will now require certain entities to register with FinCEN by 2025.

There are new filing requirements under the Corporate Transparency Act mandating that LLCs and other entities (corporations or LPs) and their beneficial owners register with FinCEN, the federal agency charged with investigating and reducing financial crimes. If your existing LLCs, “C” or “S” corporations or LPs do not qualify for an exemption, then you must file a report with FinCEN by January 1, 2025. Companies must prepare and file their own reports directly online with FinCEN. However, law firms may provide advice and analysis on the CTA and its reporting requirements and exemptions. Applicable exemptions for automotive group entities will include the “large operating company”, “securities reporting issuer” and “subsidiary” exemptions. An entity-by-entity analysis is required to verify eligibility for any exemption.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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