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FinCEN BOI Reporting Compliance Under the Corporate Transparency Act

The New York LLC Transparency Act (NY LLCTA) takes effect on January 1, 2026. It mandates that limited liability companies (LLCs) in New York disclose beneficial owner information to the New York Department of State (NYDOS). This act aligns with the federal Corporate Transparency Act (U.S. CTA), effective from January 1, 2024, and managed by the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN). Despite similarities, there are crucial distinctions between both acts.

Understanding the Scope

The NY LLCTA specifically targets LLCs in New York. In contrast, the U.S. CTA covers a broader range of domestic and foreign entities in the U.S.

Key Due Dates for Compliance

Initial Reports:

  • Post-January 1, 2026: LLCs have 30 days for compliance.
  • Pre-January 1, 2026: Compliance required by January 1, 2027.

Annual Reports:

  • Confirm or update ownership details annually.

Corrected Reports:

  • File within 90 days of discovering inaccuracies for NY LLCTA and 30 days for U.S. CTA.

Exemption Criteria

LLCs may qualify for exemptions but must file an attestation under penalty of perjury within 30 days of formation or qualification.

Disclosure Specifics

Under NY LLCTA, disclose each beneficial owner’s full legal name, birth date, address, and an identifying number from a valid ID. Unlike the U.S. CTA, no copy of the ID document is required, and a FinCEN ID cannot be used.

Penalties for Non-Compliance

Failure to file can lead to suspension and fines up to $500 per day. These penalties underscore the necessity of timely compliance.

Electronic Filing and Confidentiality

Both the NY LLCTA and U.S. CTA require electronic filings. The NYDOS maintains a secure, confidential database of beneficial ownership information.

Why Choose Us for Your BOI Reporting Needs?

Our deep understanding of corporate law and FinCEN compliance equips us to offer unparalleled support in navigating your reporting obligations. We ensure your business adheres to these essential regulations.

Act Now to Ensure Compliance and Avoid Penalties

Non-compliance can lead to severe penalties. Contact our law firm today to ensure your business meets these critical federal and state requirements. Secure your business’s future and maintain your peace of mind with our expert legal guidance.

Take the first step towards compliance and protection from penalties.

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