Disclose or Beware - What the Corporate Transparency Act Means for Investors and Lenders

Summary

The Corporate Transparency Act (the Act) became law on January 1, 2021, as part of the National Defense Authorization Act for Fiscal Year 2021. Under the Act, "reporting companies," which are corporations, limited liability companies, and similar entities (presumably including limited partnerships) formed in the U.S., or non-U.S. entities registered to do business in the U.S., will be required to report certain information about each beneficial owner, including their name, date of birth, current address, and a unique identifying number from an acceptable identification document, such as a driver's license or non-expired passport number. Reporting companies will be required to file the report with the Financial Crimes Enforcement Network of the Department of the Treasury (FinCEN) upon registration or formation. Entities that already exist as of the effective date of the regulations will have a two-year grace period before reporting is required. The Act requires that the information ...