Dear Member,

Please be aware of the New Federal Reporting Requirement summarized below. You will find additional information on the US Treasury-Financial Crimes Enforcement Network website at https://www.fincen.gov/boi.

In 2021, Congress passed the Corporate Transparency Act on a bipartisan basis. This law creates a new beneficial ownership information reporting requirement as part of the U.S. government’s efforts to make it harder for bad actors to hide or benefit from their ill-gotten gains through shell companies or other opaque ownership structures.

Beneficial ownership information refers to identifying information about the individuals who directly or indirectly own or control a company.

FinCEN launched the BOI E-Filing website for reporting beneficial ownership information (https://boiefiling.fincen.gov) on January 1, 2024.
• A reporting company created or registered to do business before January 1, 2024, will have until January 1, 2025, to file its initial BOI report.
• A reporting company created or registered in 2024 will have 90 calendar days to file after receiving actual or public notice that its creation or registration is effective.
• A reporting company created or registered on or after January 1, 2025, will have 30 calendar days to file after receiving actual or public notice that its creation or registration is effective.

Note that penalties for willfully violating the CTA’s reporting requirements include (1) civil penalties of up to $500 (adjusted annually for inflation) per day that a violation is not remedied, (2) a criminal fine of up to $10,000, and/or (3) imprisonment of up to two years.

As the CTA is not a part of the tax code, the assessment and application of many of the requirements set forth in the regulations, including but not limited to the determination of beneficial ownership interest, may necessitate the need for legal guidance and direction. As such, since we are not attorneys, our firm is not able to provide you with any legal determination as to whether an exemption applies to the nature of your entity or whether legal relationships constitute beneficial ownership.

We have attached the BOI Introduction brochure and the filing instructions. You will find additional information and your filing options at https://www.fincen.gov/boi.

Some of the information you will need to file:
· Company name address tax ID and state of formation
· Beneficial owner information including date of birth and a form of identification (i.e. driver’s license, State ID or Passport)