Four months into complying with the Corporate Transparency Act (CTA), we have picked up a few tips that we thought would be helpful to pass along.


The CTA is a federal registration program for business owners administered by the Financial Crimes Enforcement Network (FinCEN). Compliance began January 1, 2024 and involves several disclosure requirements for entity and its beneficial owners and decision makers.  Businesses formed prior to January 1st have until the end of the year to comply, while businesses formed in 2024 have 90 days.  For more information on the CTA see CTA Background Information.

Tip 1. Calendar Each Entity’s BOI Report Compliance Deadline (as updated).

  • A reporting company created or registered to do business before January 1, 2024, will have until January 1, 2025 to file its initial beneficiary ownership information report.
  • A reporting company created or registered on or after January 1, 2024, and before January 1, 2025, will have 90 calendar days after receiving notice of the company’s creation or registration to file its initial BOI report. This 90-calendar day deadline runs from the time the company receives actual notice that its creation or registration is effective, or after a secretary of state or similar office first provides public notice of its creation or registration, whichever is earlier.
  • Reporting companies created or registered 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 to file their initial BOI reports with FinCEN.

Tip 2. For Entities Created before January 1, 2024, Don’t Rush to Comply.

On March 1, 2024, a federal district court in Alabama declared that the CTA was unconstitutional. The relief from this ruling currently applies only to the named plaintiffs, which include the members of the National Small Business Association. While the court’s decision may offer relief to the plaintiffs, businesses must not interpret it as a blanket exemption from CTA compliance.

While we believe that entities created before January 1, 2024 will have to comply, there is nothing wrong with waiting until September or October before doing so.    If you choose this option, make sure to stay informed about evolving legal interpretations and regulatory guidance to ensure adherence to compliance requirements and comply by the end of the year if there is no broader relief.

Tip 3. Each Owner or Decision Maker should obtain a FinCEN Identifier Number.

Prior to the entity complying with the CTA, each beneficial owner or individual exercising substantial control over the entity should obtain a FinCEN Identifier Number at Obtaining a FinCEN ID. Beneficial owners and decision makers will be required to submit personal identifying documentation, such as a driver’s license or passport. The FinCEN ID is specific to each person and may be used for all entities that require the individual’s information. Each person should keep their FinCEN ID and login information with their important papers.  The benefits of obtaining a FinCEN ID include expediting the compliance reporting for each entity, simplifying the process for updating each person’s information in the future, such as a change of address, and limiting the number of parties that have access to the person’s drivers license or passport information.

Tip 4. Utilize the BOI E-Filing Platform.

When preparing to submit the Beneficial Ownership Information (BOI) Report, businesses should utilize the BOI E-Filing platform available at BOI E-Filing System. This streamlined electronic filing system simplifies the submission process and ensures compliance with reporting requirements.  Of course, if you need assistance or prefer for us to file the report on behalf of the entity, please let us know.

Tip 5. Request a FinCEN ID for the Entity during Reporting:

During the submission of the BOI Report, check the box labeled “Request to receive FinCEN ID” in the “Reporting Company” tab. This action facilitates the issuance of a FinCEN ID Number for the entity, enabling seamless compliance with regulatory obligations in the future.

Tip 6. Maintain CTA Compliance Documentation.

Upon completing and submitting the BOI Report, businesses should retain a transcript of the filing for their records. It is advisable to keep a copy of the transcript in the company’s minute book and provide a copy to legal counsel or accounting professionals, for record-keeping purposes.

Tip 7. Determining Who is a Beneficial Owner or Decision Maker.

Determining who is a beneficial owner or decision maker under the CTA can be complex and requires a thorough understanding of regulatory requirements and legal nuances. Businesses are encouraged to seek professional guidance to ensure accurate and timely compliance with the CTA.


If you would like DeAngelis Legal to assist you determine who is a beneficial owner or decision maker or comply with the reporting requirements, please give us a call at 480-281-1512.