News & Analysis as of

Beneficial Owner Comment Period

Kelley Drye & Warren LLP

FinCEN Exempts Domestic Reporting Companies and Persons from CTA Reporting Requirements

On March 26, 2025, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an interim final rule which narrows the scope of existing beneficial ownership reporting requirements under the...more

Fenwick & West LLP

The Corporate Transparency Act: FinCEN Removes Reporting Reqs for US Companies and Persons, Sets New Deadlines for Foreign...

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In a press release issued on March 21, 2025, FinCEN issued an interim final rule (IFR) revising the definition of “reporting company” to mean only those entities formed under the laws of a foreign country that have registered...more

Clark Hill PLC

Only Foreign Entities Need to Report Under the CTA

Clark Hill PLC on

On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN), a bureau of the Treasury Department, issued a new interim final rule on reporting under the Corporate Transparency Act (CTA). The new rule drastically...more

Montgomery McCracken

Corporate Transparency Act No Longer Applies to Entities Formed in the U.S.

Montgomery McCracken on

On March 26, 2025, the Financial Crimes Enforcement Network (“FinCEN”), a division of the United States Department of the Treasury, published in the Federal Register an interim final rule that substantially narrows the...more

Seyfarth Shaw LLP

FinCEN Narrows Scope of Corporate Transparency Act

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On March 26, 2025, the Financial Crimes Enforcement Network’s (“FinCEN”) interim final rule (the “Interim Rule”) exempting domestic entities and U.S. persons from reporting beneficial ownership information (“BOI”) under the...more

Rivkin Radler LLP

Corporate Transparency Act Obligations for U.S. Companies Are No More

Rivkin Radler LLP on

After many years of ups and downs, legal challenges, injunctions and deadline changes, the reporting obligations under the Corporate Transparency Act (CTA) have disappeared…for most. On Friday, March 21, 2025, the Financial...more

McGlinchey Stafford

FinCEN Drops Interim Rule on Reporting for U.S. Companies, But It Ain’t Over ‘Til It’s Over

McGlinchey Stafford on

Right on schedule, on March 21, 2025, FinCEN issued an Interim Final Rule that exempts U.S. companies and persons from the requirement to report, modify, or correct beneficial ownership information (BOI) under the Corporate...more

Perkins Coie

Corporate Transparency Act: FinCEN Releases Interim Rule Limiting Application of CTA to Foreign Companies Registered to Do...

Perkins Coie on

On March 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) published the text of an interim rule formally revising the Corporate Transparency Act’s (CTA) definition of “reporting...more

Keating Muething & Klekamp PLL

Corporate Transparency Act Update: FinCEN Eliminates Reporting Obligations for U.S. Companies and U.S. Persons

On March 21, 2025, the Financial Crimes Enforcement Network (“FinCEN”) issued an interim final rule that significantly narrows the beneficial ownership information (“BOI”) reporting requirements under the Corporate...more

Bowditch & Dewey

Corporate Transparency Act – CTA for Foreign Reporting Companies Only

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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

Morrison & Foerster LLP

The New CTA: Calling Foreign Reporting Companies Only

Since early December of last year, the CTA has been in a state of flux. As we recently reported, FinCEN announced it would delay the reporting deadline for most companies to March 21, 2025, and that it would provide any...more

Ballard Spahr LLP

FinCEN Issues Proposed Reporting Form for Residential Real Estate Deals

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As we previously blogged, the Financial Crimes Enforcement Center (“FinCEN”) published Anti-Money Laundering Regulations for Residential Real Estate Transfers (“Final Rule”) regarding residential real estate. The Final Rule,...more

BCLP

FinCEN Proposes AML/CFT Rules for Investment Advisers

BCLP on

On February 13, 2024, the U.S. Treasury Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking regarding a new proposed rule that would require certain investment advisers to apply anti-money...more

Stinson LLP

FinCEN Proposes Expanding AML Rules to Investment Advisers

Stinson LLP on

On February 13, 2024, the Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of Treasury (Treasury) issued a "Notice of proposed rulemaking" (proposed rule) that would require Securities Exchange Commission...more

Troutman Pepper Locke

FinCEN's Proposed New Rule to Increase Reporting Requirements in Residential Real Estate

Troutman Pepper Locke on

On February 7, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) proposed a new rule to increase reporting requirements for nonfinanced, entity-purchased residential real estate. FinCEN...more

Spilman Thomas & Battle, PLLC

Promissory Notes - Banking & Finance Insights: V 3, Issue 8, November 2023

FTC Amends Safeguards Rule to Require Non-Banking Financial Institutions to Report Data Security Breaches - “Amendment will require non-bank financial institutions to report when they discover that information affecting...more

Davis Wright Tremaine LLP

Banking and Consumer Regulatory Digest - November 2023

The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically focusing on:...more

Ballard Spahr LLP

CTA Round-Up: FinCEN Proposes Extended CTA Filing Deadline, Revised Reporting Form, and Privacy Act Exemption; Expands CTA FAQs;...

Ballard Spahr LLP on

The Financial Crimes Enforcement Network (“FinCEN”) has issued a flurry of publications relating to the Corporate Transparency Act (“CTA”).  They pertain, in part, to a proposed extension of the filing deadline for certain...more

Holland & Knight LLP

Florida Law Limits Persons from Foreign Countries of Concern from Acquiring Real Property

Holland & Knight LLP on

Now the subject of a lawsuit seeking to enjoin it, Florida Senate Bill 264 (CS/CS/SB 264), codified at Chapter No. 2023-33, Laws of Florida, would limit select persons from "foreign countries of concern" from directly or...more

White & Case LLP

SEC Reopens Comment Period on Proposed Rule Amendments to Modernize Beneficial Ownership Reporting

White & Case LLP on

On April 28, 2023, the Securities and Exchange Commission ("SEC") reopened the comment period for proposed amendments to modernize the rules governing beneficial ownership reporting under the Securities Exchange Act of 1934...more

Mayer Brown Free Writings + Perspectives

SEC Reopens Comment Period for Proposed Rule Amendments to Modernize Beneficial Ownership Reporting

On April 28, 2023, the Securities and Exchange Commission announced that it was reopening the comment period for the proposed amendments to modernize the rules governing beneficial ownership reporting filed on Schedules 13D...more

Cooley LLP

SEC reopens comment period for proposal to amend beneficial ownership reporting rules

Cooley LLP on

In February last year, the SEC proposed to amend the complex beneficial ownership reporting rules—most notably, the timing of Schedules 13D and 13G filings. In the press release announcing the proposed changes in beneficial...more

Wilson Sonsini Goodrich & Rosati

SEC Reopens Comment Period for Proposed Amendments to Beneficial Ownership Reporting Rules

On April 28, 2023, the U.S. Securities and Exchange Commission (SEC) reopened the comment period for its rulemaking proposal, Modernization of Beneficial Ownership Reporting, through the later of 30 days after the reopening...more

McGlinchey Stafford

FinCEN Invites Comment on Final Beneficial Ownership Information Reporting Rule

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On January 17, 2023, the Financial Crimes Enforcement Network (FinCEN) published a notice inviting comment on the Beneficial Ownership Information Reporting Requirements final rule (Final BOI Reporting Rule) that was...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

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