Client Alert: FinCEN Seeks Public Comment on the Corporate Transparency Act’s Beneficial Owner Reporting Requirements
Publications
April 28, 2021
On April 5, 2021, the Financial Crime Enforcement Network (FinCEN), the enforcement arm of the United States Treasury, issued an Advance Notice of Proposed Rulemaking (Notice) seeking comment on the implementation of the Corporate Transparency Act (Act). FinCEN posed 48 questions to the public regarding the Act, a bill that Congress enacted in January 2021. The Act requires certain organizations that are incorporated or doing business in the United States to disclose to FinCEN specified information on their beneficial owners. The Act also directs FinCEN to establish a national database of that beneficial ownership information. Responses to the Notice are requested on or by May 5, 2021. FinCEN must promulgate its final rules by January 1, 2022.
FinCEN’s 48 questions serve as a possible guide to FinCEN’s goals, which appear to be an accurate and detailed national database of beneficial ownership information that could clarify complex ownership structures and reveal important associations between corporate entities and beneficial owners. FinCEN’s 48 questions suggest that FinCEN is interested in strengthening the Act’s ability to detect and cut through complex ownership structures.
This alert was republished by the Harvard Law School Forum on Corporate Governance.
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© 2026 Jenner & Block LLP. Attorney Advertising. Jenner & Block LLP is an Illinois Limited Liability Partnership including professional corporations. This publication, presentation, or event is not intended to provide legal advice but to provide information on legal matters and/or firm news of interest to our clients and colleagues. Readers or attendees should seek specific legal advice before taking any action with respect to matters mentioned in this publication or at this event. The attorney responsible for this communication is Brent E. Kidwell, Jenner & Block LLP, 353 N. Clark Street, Chicago, IL 60654-3456. Prior results do not guarantee a similar outcome. Jenner & Block London LLP, an affiliate of Jenner & Block LLP, is a limited liability partnership established under the laws of the State of Delaware, USA and is authorised and regulated by the Solicitors Regulation Authority with SRA number 615729. Information regarding the data we collect and the rights you have over your data can be found in our Privacy Notice. For further inquiries, please contact dataprotection@jenner.com.
Publications
April 28, 2021
On April 5, 2021, the Financial Crime Enforcement Network (FinCEN), the enforcement arm of the United States Treasury, issued an Advance Notice of Proposed Rulemaking (Notice) seeking comment on the implementation of the Corporate Transparency Act (Act). FinCEN posed 48 questions to the public regarding the Act, a bill that Congress enacted in January 2021. The Act requires certain organizations that are incorporated or doing business in the United States to disclose to FinCEN specified information on their beneficial owners. The Act also directs FinCEN to establish a national database of that beneficial ownership information. Responses to the Notice are requested on or by May 5, 2021. FinCEN must promulgate its final rules by January 1, 2022.
FinCEN’s 48 questions serve as a possible guide to FinCEN’s goals, which appear to be an accurate and detailed national database of beneficial ownership information that could clarify complex ownership structures and reveal important associations between corporate entities and beneficial owners. FinCEN’s 48 questions suggest that FinCEN is interested in strengthening the Act’s ability to detect and cut through complex ownership structures.
This alert was republished by the Harvard Law School Forum on Corporate Governance.
Related Lawyers
Related Capabilities
© 2026 Jenner & Block LLP. Attorney Advertising. Jenner & Block LLP is an Illinois Limited Liability Partnership including professional corporations. This publication, presentation, or event is not intended to provide legal advice but to provide information on legal matters and/or firm news of interest to our clients and colleagues. Readers or attendees should seek specific legal advice before taking any action with respect to matters mentioned in this publication or at this event. The attorney responsible for this communication is Brent E. Kidwell, Jenner & Block LLP, 353 N. Clark Street, Chicago, IL 60654-3456. Prior results do not guarantee a similar outcome. Jenner & Block London LLP, an affiliate of Jenner & Block LLP, is a limited liability partnership established under the laws of the State of Delaware, USA and is authorised and regulated by the Solicitors Regulation Authority with SRA number 615729. Information regarding the data we collect and the rights you have over your data can be found in our Privacy Notice. For further inquiries, please contact dataprotection@jenner.com.
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