The Corporate Transparency Act (CTA) imposes new reporting requirements on non-exempt companies to enhance transparency and combat illicit activities. This blog post outlines the key deadlines for non-exempt companies under the CTA, focusing on those in existence as of December 31, 2023, those created on or after January 1, 2024, and those created on or after January 1, 2025, with a specific focus on Texas jurisdiction. 

Non-Exempt Companies in Existence as of December 31, 2023

For non-exempt companies that were created or registered before January 1, 2024, the CTA mandates that these entities file their initial beneficial ownership information (BOI) report by January 1, 2025. This deadline provides a one-year window for existing companies to comply with the new reporting requirements. It is crucial for such companies to gather and verify the necessary information about their beneficial owners to ensure timely and accurate reporting. 

Non-Exempt Companies Created on or After January 1, 2024

The reporting requirements for non-exempt companies created on or after January 1, 2024, but before January 1, 2025, have been temporarily adjusted. Initially, these companies were required to file their initial BOI report within 30 days of formation. However, an Extension Amendment issued on September 28, 2023, extended this deadline to 90 days. This extension aims to provide newly formed companies with additional time to understand and comply with the new reporting obligations. Therefore, any non-exempt company formed during this period must file its initial BOI report within 90 calendar days of its formation. 

Non-Exempt Companies Created on or After January 1, 2025

For non-exempt companies created on or after January 1, 2025, the deadline for filing the initial BOI report reverts to 30 days from the date of formation. This change underscores the importance of prompt compliance with the CTA's reporting requirements for newly formed entities. Companies formed in this period must be prepared to quickly gather and submit the necessary information about their beneficial owners to avoid potential violations. 

Suggested Compliance Strategies for Reporting Companies

To ensure compliance with the CTA, non-exempt companies should consider implementing the following strategies:

• Early Preparation: Start gathering beneficial ownership information well in advance of the reporting deadlines.

• Policy Development: Develop internal policies and procedures to streamline the collection and reporting of BOI.

• Legal Consultation: Seek advice from legal professionals to navigate the complexities of the CTA and ensure accurate reporting. 

Conclusion

The Corporate Transparency Act introduces significant reporting obligations for non-exempt companies, with varying deadlines based on the date of formation. Companies in existence as of December 31, 2023, have until January 1, 2025, to file their initial BOI report. Those created between January 1, 2024, and December 31, 2024, benefit from a 90-day reporting window, while companies formed on or after January 1, 2025, must comply within 30 days. By understanding these timelines and preparing accordingly, companies can ensure compliance and avoid potential penalties. 

If you have any questions or need assistance with compliance, please do not hesitate to contact Glavy Law by email, bud.glavy@glavylaw.com or by telephone, 210-880-1777.