If you are an owner, director, or manager of a company with 20 or fewer employees, you should be familiar with the CTA and its reporting requirements. Because each company is responsible for its own reporting obligations, the information in this Small Business Alert is intended to be a useful resource in helping you, as a company owner or manager, fulfill your reporting obligations. Please refer to the resource links shown below.

CTA Reporting Summary
A Beneficial Ownership Information Report (BOIR) must be completed for each reporting company. The BOIR will ask for:

1) “Company” information;
2) “Applicant” information (the person who filed company formation documents with the Secretary of State); and
3) “Beneficial Owner” information for each Beneficial Owner.

For companies formed before January 1, 2024, it is not necessary to report “Applicant” information.

Reporting Tips:
Applicant If Sound Estate Planning filed formation documents for your company after January 1, 2024, please call our office. Once we confirm that we filed the formation documents, we will provide you with Leonard Hagen’s FINCEN ID (the FINCEN ID is all you will need to include under the “Applicant” information Section of the BOIR).

Beneficial Owner If you are the Beneficial Owner of numerous companies, you can apply for a FINCEN ID. You, or anyone reporting for the company, can then simply use your FINCEN ID rather than republishing Beneficial Owner information for each reported company.

Revocable Living Trusts Under the CTA, only individuals are reported as Beneficial Owners. Thus, if your company is owned by your Revocable Living Trust (for example), then you as the Grantor or Trustee are still the only reported Beneficial Owner for the company. The Trust itself would not be included in the company report.

Legal Assistance Because our services focus on estate planning, Sound Estate Planning will not be completing CTA Reports for companies. If you need legal assistance, please contact your business attorney, or you can contact us for a business attorney referral.

Resource Links
Introduction to BOI Reporting
Need to Report Decision Tree – Focus on Substantial Control and Ownership Interest
Reporting Chart – Information and Dates
The Corporate Transparency Act

FINCEN REPORTING: https://www.fincen.gov/boi
FINCEN Frequently Asked Questions: https://www.fincen.gov/boi-faqs