Beneficial Ownership

PLEASE READ REGARDING FEDERAL LAW REQUIREMENTS THAT MAY IMPACT YOUR BUSINESS:

Enacted by Congress in 2021, the Corporate Transparency Act (CTA) calls for the implementation by the Financial Crimes Enforcement Network (FinCEN) of a Registry that retains information on beneficial owners of ‘Reporting Companies.’ Beneficial Owners include individuals who, either directly or indirectly, own or control 25% of a reporting company’s ownership or any individual who, either directly or indirectly, exercises ‘Substantial Control’ over the entity (such as executives, senior officers, and board directors) even if they do not hold an ownership interest in the entity.

Beginning January 1, 2024, ‘Reporting Companies’ will be required to submit to FinCEN a “BOI Report” containing information related to the beneficial ownership and company applicant of the Reporting Company (to be retained in the FinCEN Registry database):

• Reporting Companies created/registered prior to January 1, 2024, will have until January 1, 2025, to file initial BOI Report
• Reporting Companies created/registered on or after January 1, 2024, but before January 1, 2025, will have 90 calendar days from creation/registration to file an initial BOI Report
• Reporting Companies created/registered on or after January 1, 2025, will have 30 calendar days from creation/registration to file an initial BOI Report

See below for a link to FinCEN’s Beneficial Ownership Information (BOI) page, which includes information on how to submit beneficial ownership information to FinCEN’s Registry, as well as additional links to the regulation text and related Frequently Asked Questions. Please note, the provision of this data by Key is intended only as reference for Key’s business customers and does not constitute legal advice. Please consult with your business counsel for questions related to the CTA requirement and its application to your business.

Beneficial Ownership Information Reporting | FinCEN.gov