After a federal judge lifted a preliminary injunction on Feb. 17, the U.S. Treasury Department can now enforce the Corporate Transparency Act, a law that mandates that certain businesses must file beneficial ownership information (BOI) with the federal government.

  • BOI refers to information about the individual people who directly or indirectly own at least 25% of a company or exercise “substantial control” over the company.


That means the vast majority of PPAI’s roughly 15,000 member companies are subject to a reporting requirement due by March 21, according to the Treasury Department’s Financial Crimes Enforcement Network (FinCEN).

FinCEN says it will provide an update before then of any further modification of this deadline, recognizing that reporting companies may need additional time to comply with their BOI reporting obligations.

  • Failure to comply can trigger civil penalties (up to roughly $600 per day) and criminal penalties (up to two years’ imprisonment and a fine of up to $10,000).
  • Both individuals and corporate entities can be held liable for “willful violations.”


Earlier this week, District Judge Jeremy Kernodle of the Eastern District of Texas paused his nationwide injunction, citing the Supreme Court’s ruling in January.

Small Businesses – Including Most PPAI Member Firms – Must File

Every business entity created by filing a document with a secretary of state or equivalent office must file a BOI report, unless it qualifies for one of 23 exemptions, which include but are not limited to financial services providers, insurance companies and certain tax-exempt entities.

Large operating companies that employ more than 20 full-time employees in the United States, maintain an operating presence at a physical office within the U.S. and filed a federal income tax return for the previous year demonstrating more than $5 million in gross receipts or sales are also exempt.

  • Small businesses with fewer than 20 employees and less than $5 million in gross receipts must file. This describes the vast majority of PPAI member firms.
  • Companies formed under the law of a foreign country that have registered to do business in the United States by the filing of a document with a secretary of state or any similar office also must file.
  • A domestic entity such as a statutory trust, business trust or foundation, as well as a foreign entity, must file only if it was created by the filing of a document with a secretary of state or similar office.


Information Required For Each Beneficial Owner

  • Name
  • Date of birth
  • Address
  • Number, issuer and image of a U.S. driver’s license, passport or other government-issued identification document.


While the information listed above is for each individual beneficial owner, the report also requires similar information about the company, such as its name and address. In addition, new companies created in 2024 must submit information about the individuals who formed the company.

Individuals who do the filing should be prepared to provide basic contact information for themselves as well, including name and email address or phone number.

MORE RESOURCES