When you first opened your Salal business account, or when you last made a significant change to your existing account, you may recall being asked to complete a form outlining the beneficial ownership of your business. Beneficial owners include all individuals who own 25% or more of your business. In addition to requiring the names and information of up to four of these beneficial owners (adding up to 100%), the required form also asks for the name of your business’s primary control person, who is the individual most responsible for making decisions at your business.
We appreciate you assisting with this compliance prerequisite, and now, we want to make sure you’re aware of an additional federal requirement that went into effect on January 1, 2024. The change requires new businesses to report their beneficial owners to the national Financial Crimes Enforcement Network (FinCEN) within 90 days of creation or registration, and existing businesses will be required to file their current beneficial ownership information report by January 1, 2025.
These requirements have arisen with the Corporate Transparency Act (CTA) of 2020, which is part of the Anti-Money Laundering Act of 2020. The CTA requires corporations, LLCs, and similar business entities to submit beneficial owner information when incorporating or registering their business with their state. FinCEN will then oversee a new database containing this information.
For further information on these requirements and how to file, FinCEN has published several helpful resources:
- A short introductory video of the beneficial ownership reporting requirements.
- A frequently asked questions document.
- A list of key questions for stakeholders.
- A list of beneficial ownership report filing dates.
- An instructional video on the requirements.
- Several ways to contact FinCEN with your questions.
We know compliance requirements can feel burdensome, but there’s (potential) good news. FinCEN will eventually allow credit unions, such as Salal, to access their database of beneficial owners. This access will ensure business members are burdened with one less item to submit as we keep up with ongoing compliance paperwork we’re required to collect. Until then, we appreciate your prompt attention to our compliance requests. If you have any questions, please reach out to your Account Officer.
