Filing the Corporate Transparency Act (CTA) Report for LLCs: A Step-by-Step Guide

We wanted to talk a little bit today about the Financial Crimes Enforcement Network, also known as Finsen. There is a new act that as of January 1, 2024, is going to affect our clients who own llcs. That is called the CTA act. That’s the Corporate Transparency act. Just a little bit of background on this. This was actually something that goes back to 2021, and it is an effort to reduce money laundering, funding of terrorism activities, and so forth within the United States. So anyone who’s an owner of an LLC is going to be asked to file an additional report this year starting January 1, which discloses information regarding the beneficial ownership of said llcs. Most llcs are going to be subject to this requirement. There is a list of exemptions that is available online. We will give you that information as well. There are 23 instances for exemptions. Today we wanted to share with you an actual screen recording of how you would go about filing this information. It’s actually quite simple. It just requires you to have a little bit of information at your fingertips before you access the system. You need to know your full name of your LLC, the EIN or tax id number for your LLC, the full name, date of birth, residential address for every beneficial owner within your LLC, and then you also need to have a JPEG version of an identification for that person. So that can be a state issued id, a driver’s license or a passport, either United States or a foreign passport. So if you have all of those items at your disposal, you’re ready to file. So up on your screen, we’re going to get started showing you how you actually would go about this. So you’ll go to Fin Govboi and on your screen, this is going to pull up the main screen for the BOI filing. You’re going to see a couple of things here. Number one, there’s a big alert here in the middle. We have received notification that some clients have received emails from various legal companies offering to file this information on their behalf for a fee. We do not recommend that you click any of those. It’s actually such a quick process as well. There’s really no need to pay for that service, and your advisor here at EWA is happy to help you with all of this. So what you’re going to see on your screen as well is an option to file a report using the BOI e filing system or to create a Finsen id, which again is optional. There is a little bit of value in creating an id. So first and foremost, that id is for individuals. It’s not for your company. So, for example, if myself and my husband were the beneficial owners of an LLC, I could create a Finsen id for both he and I could go in and when I’m doing the filing, I would actually add that id number which would be linked to our personal information versus filling out the forms. So again, it could save you some time if these members are members of multiple llcs and you’d be filing multiple forms. So we can go ahead and just click where it says to file a report using the BoIe filing system. And once you’re in here, this is pretty easy. It’s going to ask you to get started up here on the right, the beneficial owner reporting system. And you do have an option to download a PDF and then subsequently upload a PDF for your filing. But the quickest way to do this is to prepare and submit online. And you’re going to notice you have five tabs. So you have filing information, reporting company, company, applicants, beneficial owners, and then the submission. So very quickly to note, if your company was in existence prior to January 1 of 2024, you have until the end of this calendar year to file this initial report. If you have a new entity that’s established in 2024, you have 90 days from the establishment of that entity to file. And then after January 1 of 2025, you need to do so within 30 days. Also see on your screen the option to correct a prior report, update a prior report or report exempt entity, which basically means if your entity has changed and you now qualify for an exemption, you would go in and file that item d to let them know that you are now exempt from future filing. So we’re going to go through just an initial report and we’re going to just use some basic info here to give you an idea of what you need to fill in. So it will actually auto fill the date. And then you’re going to go ahead and select number three here to request your Finsen id for your company. You’re going to go ahead and put in the name of your llc. So we’ll just use EWA. And now EWA also does business as equilibrium wealth advisors. So we’ll go ahead and note that DBA here, and then we’ll go ahead and enter our tax id for our entity. Something to note here is that you do not want to use dashes when entering this. And then you’re also going to select the country if it is a foreign id only. So you’re going to select United States of America. This is where your company was located, your state of formation, this could be different than where the primary business is located. So, for example, if you created your LLC in Delaware, you would select that even if your place of business is in the state of Pennsylvania, and you can put in your business address here, and you’re going to select again, United States, your state, and zip and just hit next. All right, so this is where you are going to be able to utilize a fin send id. Had you created that on the previous screen. If not, you can skip over item 18 and go directly to the section 19, which is going to be the primary member or owner of the LLC. This is a person typically that is going to also complete the form. So we will go ahead here and add our CEO, Matt Blocky. You’re going to want to put a date of birth in here. And then this gives you the option of utilizing a business address or a residential address. In this case, we’ll go ahead and use the business address because we will be asked for a residential address in the next section. And then this is where you’re going to really need to have that identification kind of at your fingertips. So again, you can use a state id, state driver’s license, us or foreign passport. So we will go ahead and do our state driver’s license. You do need to enter the number on the document here. Again, we’re just kind of using some dummy information here to kind of illustrate how easy this is in the United States. And then the state that issued the document, if it is a state issued id, and you’re going to select from the desktop here, we will select our driver’s license. We will open that. And again, it has to be in a JPEG format. It will be rejected if it’s not. So actually taking a photo of the id, passport, et cetera, on your cell phone, emailing that to yourself, typically that will put that in a JPEG format. So super easy. And then we’ll also get to the screen here real quick. This is the meat of the information, which is the beneficial owner information. So if you are the only member of an LLC, you’re the only owner. This is the only screen that you’re going to complete. If you have multiple beneficial owners, you’re going to go up here and click add beneficial owner, and that’s going to add multiple parties to this same screen. You can also remove these if you accidentally added too many members. And again, if you did create a Finsen id for this individual, you can enter that here. If you are filling this in as a parent or guardian of a minor, you can also select item 35. And then if you’re an exempt entity, you’re going to select number 37. And that would be if you’re indicating that you’re now exempt on a previously filed report. So let’s assume once again that Matt is our only owner and member. So we’ll go ahead and put him in. And again, just some dummy information here. And we’ll go ahead and put a residential address in. So this is the differentiator from the previous screen. So now that we’re talking about the member versus the company, we can go ahead and put a residential address in here versus the company address. Again, the United States state and zip. And you are going to be asked to re upload the document and reenter in your information. So I would go ahead and recommend that you save all of your identification documents to your desktop or your documents folder prior to going through this process. It’s just going to make it so much easier. And we are going to, once again, United States state of Pennsylvania and we are going to click next. Now you will go ahead and complete that for every member. Once again, or every beneficial owner. When you get to this screen here, it’s going to ask you the email address that you’d like to receive, a confirmation and a tracking number so you can go ahead and put in your email. And you’re going to go ahead and agree that you’re authorized to file this report on behalf of the LLC or entity. You’re going to select that you’re a human. Then this button right here where it says submit Boir is going to become live. You’re going to go ahead and click that and you’re going to get a confirmation on your screen as well as to your email. Highly recommend that you keep those in a file should anything change with your LLC. So if the beneficial owners change, if you found that there is an error in the filing that you did, you will come back to thefinsend Gov Boir and you can file that correction, that update, et cetera there. Well, we hope this video was very helpful to those of you who are LLC owners or beneficial owners of llcs. If you have any questions on this process, if you receive emails that are questionable, please feel free to reach out to us here at EWA. Your financial advisor, a member of our team, is always available to help you. If there’s anything we can do to clarify or help you file these forms, we’re happy to do so.