Under the Federal Corporate Transparency Act (CTA) businesses have until January 1, 2025 to file their initial beneficial ownership information (BOI) reports. These new reporting requirements were created in 2021 under the CTA to strengthen the integrity of the U.S. financial system by making it more difficult for illicit actors to use anonymous
shell companies to launder their money or hide assets.

BOI reports should be filed through FinCEN’s website at https://www.fincen.gov/boi.

Beneficial ownership information reported to FinCEN will be stored in a secure, non-public database using rigorous
information security methods and controls typically used in the Federal government to protect non-classified yet sensitive information systems at the highest security level.

Exemptions
23 types of entities are exempt from the beneficial ownership information reporting requirements. These entities include publicly traded companies meeting specified requirements, many nonprofits, and certain large operating companies.

Two of the exemptions may apply to dealers and their related entities.
1. Being a large operating company; and
2. Being a subsidiary of an exempt entity (such as a large operating company).

To use the “large operating company” exemption, the entity must meet six factors, which include having 20 full-time
employees that are employed in the United States, having a physical presence in the United States, and having filed
a federal tax return for the previous year demonstrating at least $5,000,000.00 in gross receipts or sales.

To use the subsidiary exemption, the entity need only be controlled or wholly owned, directly or indirectly, by another exempt entity. To further review exemptions and for a list of frequently asked questions, visit https://www.fincen.gov/boi-faqs.

Willful failure to complete a BOI report or willfully providing false information may result in civil and criminal penalties
including $500 daily fines. Complete BOI reports through FinCEN’s website before January 1, 2025 at https://www.fincen.gov/boi.