CTA Status Report – Interim Final Rule 03/21/25

By: Brett A. Hodges

On March 21, 2025, the Treasury Department, through the Financial Crimes Enforcement Network (FinCEN) issued an interim final rule regarding the reporting requirements under the Corporate Transparency Act (CTA).  Under the CTA, all entities that were considered “reporting companies” were required to report their beneficial ownership information to FinCEN.  This meant that virtually all entities that were created through a filing with the State were required to report their beneficial ownership information to FinCEN.

However, under the interim final rule, domestic reporting companies (i.e., companies that were formed in the United States) are not required to report their beneficial ownership information to FinCEN. This, of course, has greatly reduced the number of entities which must comply with the CTA. Foreign reporting companies, which are companies that were formed outside of the United States that register to do business in the United States, are still required to report their beneficial ownership information. Foreign reporting companies who register to do business within the United States have 30 days from the date of their registration to file their beneficial ownership information reports.

While US business owners can rest easy knowing that there is no longer a reporting obligation under the CTA, it is important to remain aware of the fact that further changes may occur. This is an interim final rule, and interim rules are subject to change. FinCEN will be accepting comments on the file rule until May 27, 2025.