In prior blogs, I discussed how the Corporate Transparency Act (“CTA”) will require most existing and new corporate entities (e.g., corporations, limited liability companies, etc.) to report personal information about the entity’s owners and those who formed/incorporated the entity. On September 30, 2022, the United States Department of Treasury (“Department”) published a 99-page notice of its final rule regarding the Beneficial Ownership Information Reporting Requirements. This blog touches upon two key components of the rule.

Effective Date and Deadlines…

The final rule is effective January 1, 2024. Covered entities organized or formed prior to that date will have one year to file their initial Beneficial Ownership Information report with the Department. All covered entities formed after the effective date will have 30 days after formation/incorporation to file their report.


In addition to information about entity owners, covered entities are required to report personal information regarding applicants (i.e., anyone who files a document to form/incorporate a covered entity as well as anyone who directs or controls the filing of such a document by another person). During the public comment period, a great deal of concern was expressed regarding the difficulty (if not impossibility) of ascertaining the required information for entities that had been formed many years (if not decades) ago. Fortunately, the final rule does not require entities that existed prior to the effective date of the rule to report information on their applicants.


 The final regulations will continue to be analyzed in the coming weeks and months. Please stay tuned or reach out to me for more information about how this may impact you and your company.


PLEASE NOTE: This blog is merely for the general interest of the reader. It is not legal advice or opinion and it does not create an attorney-client relationship. Please call me at 973-921-0600 if you’d like to have a free initial telephone consultation or learn more about me or my practice. Thank you.