The Corporate Transparency Act: New Reporting Requirements

Mariel Giletto, Anthony Gruzdis

PLEASE TAKE NOTE: Beginning on January 1, 2024, the Corporate Transparency Act (“CTA”) goes into effect. The CTA imposes new federal reporting requirements on most organizations formed or doing business in the United States. These reporting requirements (the “Required Disclosures”) pertain to information relating to the following three categories: (1) the organization (the “Reporting Company”); (2) the beneficial owners of the Reporting Company (the “Beneficial Owners”); and (3) the individuals who directed the creation of the Reporting Company (the “Company Applicants”).  This Alert updates and refreshes our prior Alert on the CTA, which was published on May 18, 2021.

New Reporting Requirements

In general, under the CTA:

After the initial filing with FinCEN, all Reporting Companies, Beneficial Owners, and Company Applicants must report any changes to the Required Disclosures within 30 days of the change.


A willful failure to comply with these obligations exposes violators to civil penalties of up to $500 per day and criminal penalties of up to two years in prison.  

Summary of Required Disclosures and Applicability

Reporting Companies
Beneficial Owners
Company Applicants

State Requirements

These federal requirements are in addition to existing and future state reporting requirements. For clients located in New Jersey, these federal reporting requirements do not replace the current New Jersey annual reporting requirements. For clients located in Pennsylvania, new state reporting requirements will go into effect in 2025 requiring annual reports that disclose, among other items, the names of all principal officers and at least one governor (defined as a partner, member, or director depending on the type of business organization).

Next Steps

Please contact your attorney at Flaster Greenberg, one of the members of our firm's CTA Task Force – Jonathan Ellis, Mariel Giletto, Anthony Gruzdis, Matthew Meltzer, David Neufeld – or any attorney in the Business & Corporate Department, to discuss how we can help determine whether the CTA applies to you or your organization and, if necessary, comply with the CTA initially and moving forward.

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