FinCEN BOI FAQ C.12
Do beneficial ownership information reporting requirements apply to companies created or registered before the Corporate Transparency Act was enacted (January 1, 2021)?
Cite as FinCEN Beneficial Ownership Information FAQ C.12 (Reporting Company)
Yes. Beneficial ownership information reporting requirements apply to all companies that qualify as “reporting companies” (see Question C.1), regardless of when they were created or registered. Companies are not required to report beneficial ownership information to FinCEN if they are exempt (see Question C.2 and, generally, Section L) or ceased to exist as legal entities before January 1, 2024 (see Question C.13).