Effective January 1, 2024, the US government instituted the Corporate Transparency Act (“CTA”), which is meant “to curb illicit finance”.  Under the CTA, most companies doing business in the United States are now required to report information about the individuals who ultimately own or control them (“Beneficial Owners”).

 

In plain language, the members of LLCs and owners and officers of corporations, particularly small entities, are often not a matter of public record.  While the state agencies that oversee such businesses (in Vermont, the Secretary of State’s Office, Corporations Division) do accept the names and addresses of the Beneficial Owners, it is rarely required.  This makes it difficult for the US government to identify who actually controls and benefits from the assets of various companies throughout the US, which impedes law enforcement activities in the area of financial fraud.

 

To address this, the CTA requires companies to report the names, addresses, and dates of birth of their owners and officers, as well as provide proof of identity for those individuals.  Please note the following deadlines imposed by the CTA for filing the required Beneficial Owner Information (“BOI”):

 

 

 

 

For more information about these requirements, as well as to access the reporting portal, please visit Beneficial Ownership Information Reporting | FinCEN.gov.

 

Please note: the responsibility for filing the BOI information lies with the company, so unless you have already made arrangements with your Registered Agents or other compliance personnel, you should address these requirements in compliance with the deadlines shown here.