FinCEN Beneficial Ownership Information Reporting Requirements Advanced Notice of Proposed Rulemaking Summary

Updated 04/27/2021

This tool summarizes FinCEN’s advanced notice of proposed rulemaking covering statutory requirements put forward by the CTA and NDAA. The following are the key takeaways:

  1. The CTA and NDAA require companies to report beneficial ownership information to FinCEN.
  2. The CTA and NDAA require FinCEN to implement regulations regarding beneficial ownership reporting requirements as well as a non-public database of information collected. Some of these regulations are required to be promulgated by FinCEN by January 1, 2022.
  3. FinCEN has provided several questions to assist the agency in exercising its rulemaking authority and banks should consider those questions when submitting a written comment.

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