To:  Clients and Friends of Fox Swibel Levin & Carroll LLP

We are nearly two months away from an important Corporate Transparency Act (the “CTA”) deadline. Reporting Companies created or registered to do business in the United States before January 1, 2024 must file Beneficial Ownership Information Reports by January 1, 2025. If you would like Fox Swibel, on behalf of your Reporting Company, to file Beneficial Ownership Information Reports with FinCEN to comply with the CTA, we ask that you please submit all required Beneficial Ownership information by December 1, 2024.

FinCEN has provided guidance on how to determine Beneficial Owners in a compliance guide and an FAQ page. We have also reattached to this email:  (1) a Memorandum that provides an overview of the CTA; (2) a form outlining the information required to be filed with FinCEN (“Disclosure Form”); and (3) an article written by partner David Morris that provides detailed information regarding the CTA and its requirements and exemptions.

If you would like Fox Swibel, on behalf of your Reporting Company, to file Beneficial Ownership Information Reports with FinCEN to comply with the CTA, we will rely on the Beneficial Ownership information you provide us. With respect to all entities for which you would like us to file on your behalf, we kindly ask that you fill out and return a completed copy of the Disclosure Form via email to Megan Waters ([email protected]). If you do not complete and return the attached Disclosure Form for a Reporting Company, we will assume that you will handle your CTA compliance obligations for that Reporting Company independently.

If you have any questions about the Disclosure Form, please feel free to contact Megan Waters via email at the email address set forth above. If you have questions about the CTA or its filing requirements, please contact David Morris ([email protected]), Rick Meller ([email protected]) or Marcus Lind-Martinez ([email protected]).  Thank you.

This article contains material of general interest and should not be construed as legal advice or a legal opinion on any specific facts or circumstances.  Under applicable rules of professional conduct, this content may be regarded as attorney advertising.