On September 27, 2023, the US Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) issued a press release announcing its intention to publish a Notice of Proposed Rulemaking (NPRM) on September 28, 2023. The NPRM would extend the deadline for reporting companies created or registered in 2024 to file their initial beneficial ownership information (BOI) under the Corporate Transparency Act (CTA) (effective January 1, 2024) from 30 days to 90 days; the NPRM makes no other proposed changes.

In the press release, FinCEN also clarifies that the proposed extension is only for entities created this introductory year as filers get used to the CTA and, as proposed, will not apply to the initial BOI filings of reporting companies formed or registered before January 1, 2024, or on or after January 1, 2025. Comments on the NPRM must be submitted to FinCEN by October 30, 2023.

For more information on the CTA, including the types of entities that are reporting companies that must report their BOI under the CTA, the types of entities that are exempt from the reporting requirements, and when initial reports and changes to reports must be filed, see Practice Note, Corporate Transparency Act (CTA) Beneficial Ownership Reporting.