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Reporting Requirements Public Comment FinCEN

White and Williams LLP

Corporate Transparency Act – FinCEN Narrows Scope of Reporting Requirements and Extends Deadline

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In the latest twist in the ongoing Corporate Transparency Act (“CTA”) and beneficial ownership information (“BOI”) reporting requirements saga, news came from Washington on March 21, 2025, that the Financial Crimes...more

Ward and Smith, P.A.

Corporate Transparency Act Shakeup: Domestic Companies off the Hook, Foreign Entities Still Reporting

Ward and Smith, P.A. on

This interim final rule, released on March 21, 2025, means that only foreign entities registered to do business in the United States will still need to meet the CTA’s reporting requirements. Originally enacted to increase...more

Ballard Spahr LLP

FinCEN Exempts All Entities Created in the U.S. From the Corporate Transparency Act (CTA)

Ballard Spahr LLP on

On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) issued an Alert stating that all entities created in the U.S.—including those previously known as “domestic reporting companies”—and their beneficial owners...more

Bailey & Glasser, LLP

Client Alert: "BOI Reporting Dropped for U.S. Entities; 30-Day Extension for Foreign Companies"

Bailey & Glasser, LLP on

In the latest turn of events in the ever-evolving reporting rule saga under the Corporate Transparency Act (“CTA), on March 21, 2025, FinCEN issued an Interim Final Rule (“IFR”) and accompanying press release, aligning with...more

Chambliss, Bahner & Stophel, P.C.

CTA Reporting Rule Narrowed to Foreign Companies Only

On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) released its anticipated interim final rule for the Corporate Transparency Act (CTA)...more

Bowditch & Dewey

Corporate Transparency Act – CTA for Foreign Reporting Companies Only

Bowditch & Dewey on

On Friday, March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) issued an interim final rule that eliminates reporting requirements for domestic reporting companies via redefining “reporting company” to include...more

Fox Rothschild LLP

Corporate Transparency Act Narrowed

Fox Rothschild LLP on

The U.S. Treasury Department has significantly scaled back the reach of the Corporate Transparency Act (CTA). Under a new interim final rule released by Financial Crimes Enforcement Network (FinCEN), U.S.-formed companies...more

Flaster Greenberg PC

Corporate Transparency Act Update - FinCEN Interim Rule

Flaster Greenberg PC on

On March 21, FinCEN issued an interim rule that implements the reduced scope of the Corporate Transparency Act (“CTA”) previously announced on March 2....more

Morgan Lewis

FinCEN Will Not Enforce Extended Corporate Transparency Act Filing Deadlines

Morgan Lewis on

Corporate Transparency Act (CTA) reporting requirements were recently reinstated, and the Financial Crimes Enforcement Network (FinCEN) established a new filing deadline of March 21, 2025. However, on February 27, 2025,...more

Neal, Gerber & Eisenberg LLP

Corporate Transparency Act is Again on Hold

On February 27, 2025, FinCEN announced “that it will not issue any fines or penalties or take any other enforcement actions against any companies based on any failure to file or update beneficial ownership information (BOI)...more

White & Case LLP

FinCEN and SEC Move Closer to New AML Requirements for Investment Advisers & ERAs

White & Case LLP on

On May 13, 2024, FinCEN and the SEC jointly proposed a new rule that would require SEC-registered investment advisers and exempt reporting advisers to maintain written customer identification programs (CIPs). The new rule...more

ArentFox Schiff

Calling all Cash Money Millionaires: FinCEN Proposes New Reporting Rules for Cash Residential Real Estate Transfers

ArentFox Schiff on

“In residential real estate sales, all parties involved, including sellers, developers, title companies, attorneys, and closing agents, need to be aware of reporting requirements. Consider a situation where a commercial...more

Orrick, Herrington & Sutcliffe LLP

FinCEN solicits feedback on beneficial ownership reporting requirements

On January 17, the Financial Crimes Enforcement Network (FinCEN) published two notices and requests for comment in the Federal Register related to the reporting process the agency intends to use to collect beneficial...more

Goodwin

Stress Test Scenarios Released for 2022

Goodwin on

In This Issue. The Federal Reserve Board of Governors (Federal Reserve), the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) released stress test scenarios to assess...more

Goodwin

SEC Proposes Changes to Private Fund Regulation

Goodwin on

In This Issue. The U.S. Securities and Exchange Commission (SEC) proposed changes to private fund regulation; the Office of the Comptroller of the Currency (OCC) succeeded in validating its “valid-when-made” rulemaking; the...more

Patterson Belknap Webb & Tyler LLP

FinCEN Issues Notice of Proposed New Beneficial Ownership Information Reporting Requirements Under the Corporate Transparency Act

The Financial Crimes Enforcement Network (“FinCEN”), a bureau of the United States Department of the Treasury, published a Notice of Proposed Rulemaking (the “Proposed Rules”) on December 8, 2021 in the Federal Register. The...more

Goodwin

FinCEN Proposes Rule for SARs Sharing Pilot Program

Goodwin on

In This Issue. The Financial Crimes Enforcement Network (FinCEN) issued a proposed rule about the establishment of a limited-duration pilot program for sharing suspicious activity reports (SARs); FinCEN published the final...more

Goodwin

Agencies Launch Digital Identity Tech Sprint

Goodwin on

In This Issue. The Federal Deposit Insurance Corporation (FDIC), the FDIC Tech Lab (FDITECH) and the Financial Crimes Enforcement Network (FinCEN) launched a digital identity Tech Sprint; FinCEN published a 60-day notice to...more

Goodwin

OCC Seeks Feedback on Principles for Climate-Related Financial Risk Management

Goodwin on

In this Issue. The Office of the Comptroller of the Currency (OCC) is seeking feedback on principles for climate-related financial risk management for large banks; the Department of Justice’s Antitrust Division is seeking...more

Goodwin

FinCEN Proposes Rules Implementing Corporate Ownership Requirements Under Corporate Transparency Act to Fill Gaps in U.S....

Goodwin on

WHAT YOU NEED TO KNOW: - The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has issued a proposed rule to implement portions of the Corporate Transparency Act codified at 31 U.S.C. § 5336 (CTA). ...more

Goodwin

SEC Proposes New Round of Money Market Fund Reforms

Goodwin on

In This Issue. The U.S. Securities and Exchange Commission (SEC) voted to propose money market fund reforms; the SEC also proposed amendments to Rule 10b5-1 trading plans and to modernize and improve share repurchase...more

Goodwin

FinCEN Issues Proposed Rule for Beneficial Ownership Information Reporting Requirements

Goodwin on

In This Issue. The Financial Crimes Enforcement Network (FinCEN) announced (1) a notice of proposed rulemaking for beneficial ownership information reporting requirements and (2) a regulatory process for new real estate...more

Saul Ewing LLP

FinCEN Seeks Public Comment on Opaque Corporate Transparency Act

Saul Ewing LLP on

The Financial Crimes Enforcement Network of the Department of Treasury (FinCEN) has made it clear that the reporting obligations imposed on corporations, LLCs, and other “similar” entities under the new Corporate Transparency...more

Bilzin Sumberg

FinCEN Seeks Public Comment on Corporate Transparency Act

Bilzin Sumberg on

On April 1, 2021, the Financial Crimes Enforcement Network (FinCEN) issued an Advance Notice of Proposed Rulemaking (the "Notice") seeking public comment on a myriad of issues related to the implementation of a beneficial...more

King & Spalding

Pumping the Brakes: FinCEN Reopens Comment Period for Controversial Crypto Reporting & Recordkeeping Rules

King & Spalding on

After Widespread Market Opposition in an Expedited First Round of Comments, FinCEN Solicits More Feedback on Rule Seeking to “Close Gaps” in Virtual Currency Anti-Money Laundering Rules On January 14, in a surprise move,...more

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