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CTA Update: 90-Day Reporting Deadline
Post on February 29th, 2024

The Corporate Transparency Act (CTA), part of the Anti-Money Laundering Act provisions in the National Defense Authorization Act of 2021, took effect January 1, 2024. The CTA requires a non-exempt business entity (a “reporting company”) to report information on their “beneficial owners” (beneficial owner information – BOI) with the Financial Crimes Enforcement Network “FinCEN.”

Reporting deadlines to file the initial BOI report with FinCEN depend on when a reporting company was created or registered. See BOI Small Entity Guide. A reporting company created or registered:

  • prior to January 1, 2024 – will have until January 1, 2025 to report
  • on or after January 1, 2024, and before January 1, 2025 – will have 90 calendar days after receiving actual or public notice that their company’s creation or registration is effective
  • on or after January 1, 2025, will have 30 calendar days from actual or public notice that the company’s creation or registration is effective.

For entities created or registered on or around January 1, 2024, be aware that the 90-day reporting deadline is approaching. It’s important for the responsible filer to be aware of this 90-day reporting deadline. Your agreement undertaking representation should clearly identify who the responsible filer will be.

Additionally, a domestic reporting company created on or after January 1, 2024, or a foreign reporting company first registered to do business in the United States on or after January 1, 2024, is required to report its company applicants.  There are two categories of company applicants: the “direct filer” and the individual who “directs or controls the filing action.” See OBLIC Alert Corporate Transparency Act Launches January 1, 2024.

The Required Information Checklists in Chart 7 (Page 38) of the BOI Small Compliance Guide will help identify the information about the company, beneficial owners and company applicants that is required to be collected and reported. The BOI report is filed electronically through the FinCEN BOI E-Filing System. The website provides for several filing methods. You can select the method that works best for you.

While a FinCEN identifier is not required, having it can simplify the reporting process. See OBLIC Alert Your Hotline Questions: CTA.

For more information visit the FinCen BOI website. The website features links for how to Prepare and File, FAQs for more information, Chat portal for more information, Contact FinCEN to ask BOI questions, and link to subscribe to FinCEN Updates. 

As always, if you have questions, please feel free to contact us. Let us know if this is helpful and what you might like to hear about in the future. We’re OBLIC and we’re here to help!

Gretchen K. Mote, Esq.
Director of Loss Prevention
Ohio Bar Liability Insurance Co.
Direct:  614.572.0620
[email protected]
Merisa K. Bowers, Esq.
Loss Prevention Counsel
Ohio Bar Liability Insurance Co.
Direct:  614.859.2978
[email protected]


This information is made available solely for loss prevention purposes, which may include claim prevention techniques designed to minimize the likelihood of incurring a claim for legal malpractice. This information does not establish, report, or create the standard of care for attorneys. The material is not a complete analysis of the topic and should not be construed as providing legal advice. Please conduct your own appropriate legal research in this area. If you have questions about this email’s content and are an OBLIC policyholder, please contact us using the information above.