On March 21, the Financial Crimes Enforcement Network (FinCEN) announced an interim final rule significantly narrowing the existing beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA).

Under this interim final rule, which is effective as of March 26, entities previously defined as “domestic reporting companies” are no longer considered “reporting companies” under the CTA and are exempt from the BOI reporting requirements. Therefore, domestic reporting companies are not required to report BOI with FinCEN or update or correct BOI previously reported to FinCEN.

In addition, foreign reporting companies are exempt from having to report the BOI of any U.S. persons who are beneficial owners of the foreign reporting company and U.S. persons are exempt from having to report information to any foreign reporting company for which they are a beneficial owner.

Foreign reporting companies registered to do business in the U.S. before March 26 must file BOI reports by April 25. Foreign reporting companies registered to do business in the U.S. on or after March 26, have 30 days to file an initial BOI report after receiving notice that their registration is effective.

Taft will continue to monitor developments and implications of the CTA and provide additional alerts as information becomes available.