Part 4

What are the Reporting Obligations Under the CTA?

Initial Reports

All Reporting Companies must make an initial filing with FinCEN disclosing the necessary Beneficial Ownership information. If the initial report is for an entity formed during or after 2024, the report must include information about Company Applicants. The reporting deadlines are provided below:

Year of Formation

Initial Reporting

Before 2024



90 days after formation

After 2024

30 days after formation

Changes in Beneficial Owner or Company Information:

Whenever there are changes to the company’s information or the Beneficial Owner’s information that was previously submitted to FinCEN, the company must file a report within 30 days after the change. For companies that existed prior to 2024, the update is only required for changes that occur after the company makes its initial filing. (Changes in the Company Applicant information do not need to be reported.)

  • Death of a Beneficial Owner. If the change results from the death of an individual who was a Beneficial Owner because of property interests or other rights subject to transfer upon death, a change with respect to required information will be deemed to occur when their estate is settled, either through the operation of the laws of intestacy or through a testamentary deposition.
  • Minor Becoming an Adult. A report with updated information is required when a minor reaches the legal age of majority in the jurisdiction in which they live, if their parent or legal guardian’s information was previously provided as permitted by the CTA.
  • Becoming Exempt or Losing an Exemption. Whenever the company becomes exempt or loses an exemption, it is considered a change.
  • Correcting Inaccurate Reports. All Incorrect information must be corrected. If incorrect information is unintentionally reported, correct information must be reported within 30 days after the Company knew or should have known about the error. If the corrected report is filed within 90 days after the information was originally due, there will be no penalty.

Beneficial Owner and Company Applicants – Required Information:

  • Full legal name
  • Date of birth
  • Complete current address (use the residential street address for Beneficial Owners, and the business street address for Company Applicants if the Company Applicants filed the entity in the course of their business.)
  • Unique identifying number (such as a driver’s license number, non-expired Passport or identification issued by a state, local government or tribe), the issuing jurisdiction for that ID, and a photo of that ID
  • Instead of providing this information each time, a Beneficial Owner or Company Applicant can obtain provide a FinCEN ID instead

Reporting Company – Required Information:

  • The company’s full legal name
  • All trade names or “doing business as” (DBA) names
  • Complete current US address for the company’s principal place of business, or in the absence of a principal place of business, the US street address where the company primarily conducts its business
  • State, tribal or foreign jurisdiction of formation
  • IRS Taxpayer Identification Number (such as an EIN)


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