On November 29, 2023, the US Department of Treasury's Financial Crimes Enforcement Network (FinCEN) issued a final rule that extends the reporting deadline for certain companies to file initial beneficial ownership information (BOI) with FinCEN under final rules implementing Section 6403 of the Corporate Transparency Act (CTA) that require certain entities to file reports with FinCEN identifying and providing information about their beneficial owners and applicants (see Legal Update, FinCEN Issues Final Rule for Beneficial Ownership Reporting to Support Law Enforcement Efforts, Counter Illicit Finance, and Increase Transparency).

Under the final rule, entities created or registered on or after January 1, 2024 and before January 1, 2025 have 90 calendar days of notice of their creation or registration to file initial BOI reports with FinCEN. According to the final rule, this extension was implemented to give those entities additional time to understand the new reporting obligation and collect the necessary information to complete their filings. The final rule also provides that entities created or registered on or after January 1, 2025 will continue to have 30 calendar days to file their BOI reports with FinCEN.

According to a FinCEN press release, FinCEN will not accept BOI reports from reporting companies until January 1, 2024.

The final rule is effective January 1, 2024.