By clicking “Accept”, you agree to the storing of cookies on your device to enhance site navigation, analyze site usage, and assist in our marketing efforts. View our Privacy Policy for more information.
On August 11, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforce (“FinCEN”) issued its promised Final Rule regarding reporting requirements under the Corporate Transparency Act (the “CTA”).1 The final rule, which will be effective upon its publication in the Federal Register, permanently removes the requirement that U.S. entities and persons report beneficial ownership information (“BOI”), maintaining the exemptions from the Interim Final Rule issued on March 26, 2025. Thus comes the quiet demise of what was a relatively short-lived, but fraught, contentious and litigious process that began with the enactment of the CTA on January 1, 2021. The only surviving piece of the legislation is the requirement that foreign reporting entities registered to do business within the U.S. or Tribal jurisdictions continue to report foreign BOI.
FinCEN has stated it will delete any previously filed BOI for U.S. entities and persons from FinCEN’s BOI database. This includes information for U.S. persons connected with foreign reporting entities for which reporting requirements remain. Moreover, U.S. persons who have obtained FinCEN identification credentials will have no further obligation to update or correct the information they have already provided.
While FinCEN’s Final Rule provides closure regarding federal collection of BOI, there have been some state efforts to enact similar legislation. As of January 1, 2026, New York State requires certain LLCs formed under the law of a foreign country and authorized to do business in NYS to file initial and annual disclosure statements concerning BOI. Like the federal rule, NYS does not have a similar requirement for domestic entities. Washington, DC, requires entities formed or registered to do business there to disclose BOI at the time of creation/registration and update biennially or as changes occur. The DC ownership threshold is lower than its federal or NYS counterpart, and the requirement predates the federal CTA. Other states have proposed legislation to require BOI reporting, but as of this writing, none has been adopted. It is yet to be seen whether more states will enact BOI reporting requirements.
1 https://home.treasury.gov/news/press-releases/sb0603
Disclaimer:
This presentation has been prepared by Market Street Trust Company. The views expressed herein represent opinions of Market Street and are presented for informational purposes only. They are not intended to be recommendations or investment advice and do not take into account the individual financial circumstances or objectives of the investor who receives them.
Certain statements included in this presentation constitute forward looking statements. Forward looking statements are not facts but reflect current thinking regarding future events or results. These forward looking statements are subject to risks that may result in actual results being materially different from current expectations.
Past performance (before and after taxes) does not guarantee future performance. There is no assurance that Market Street Trust Company investments will achieve their objectives, or that they will or are likely to achieve results comparable to results shown herein, or will make any profit, or will be able to avoid incurring losses. Exposure to foreign currencies may cause additional fluctuation in the value of any investment. Each investor must assess the suitability of an investment, the investor’s tolerance for risk and the impact on the investor’s diversification strategy. This presentation does not constitute an invitation to buy or an offer to sell securities, or any other products or services.
This is intended as general information only. Investors maybe required to meet certain criteria under the securities laws in order to qualify for certain investments. Any discussion of U.S. tax matters is not intended and cannot be used or relied upon for the purpose of avoiding U.S. tax-related penalties. Please visit our website for additional information concerning Market Street’s investments and investment updates. As always, please feel free to contact us if you would like to learn more about our investment program.
