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Corporate Transparency Act's Impact on Private Funds and Investment Managers

Reporting Obligations, Exemptions From Reporting, Compliance Deadlines, Penalties

Recording of a 90-minute premium CLE video webinar with Q&A

This program is included with the Strafford CLE Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Conducted on Tuesday, September 24, 2024

Recorded event now available

or call 1-800-926-7926

This CLE webinar will provide an overview of the Corporate Transparency Act (CTA) and its requirements as they relate to private funds and their sponsors and investment managers. The panel will discuss the CTA's beneficial ownership information (BOI) reporting requirements, what entities are required to report their BOI, entities that are exempt from reporting, information that must be reported, compliance deadlines, and penalties for failing to comply.

Description

The CTA, which became effective Jan. 1, 2024, requires non-exempt legal entities to disclose BOI to the Financial Crimes Enforcement Network within certain prescribed time periods. Many domestic and foreign entities doing business in the United States need to make federal filings identifying and providing information about their beneficial owners and company applicants or face civil or criminal penalties.

Counsel representing private funds and investment managers must understand that their clients will generally fall within the scope of the CTA's BOI reporting requirements unless one of the enumerated exemptions applies. Determining whether an exemption applies requires a thorough analysis of the facts and circumstances of every entity within the fund's organizational structure to confirm whether or not it is a "reporting company" under the purview of the CTA's reporting requirements.

Listen as our expert panel offers a high level overview of the CTA while highlighting the various complexities, inquiries, and subtleties concerning the practical implications of the CTA on private funds and investment managers.

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Outline

  1. CTA overview
    1. Entities subject to the CTA's BOI reporting rule
    2. Purpose of the BOI rule and applicable effective dates
    3. Compliance requirements
    4. Information that must be reported
    5. Penalties for noncompliance
  2. CTA's impact on private funds and investment managers
    1. Relevant exemptions to the BOI reporting requirements for private funds and investment managers
    2. Analyzing facts and circumstances of a private fund's structure to determine if the entity is required to report BOI or if an exemption applies
  3. Steps private funds and investment managers must have in place to ensure compliance with the CTA's BOI reporting rule
  4. Key takeaways

Benefits

The panel will review these and other key considerations:

  • What is the BOI reporting rule under the CTA and what is its purpose?
  • What entities are subject to the BOI rule and what are the compliance requirements?
  • How does the CTA's BOI rule impact private funds and investment managers?
  • What should private funds and their managers do to ensure compliance with the CTA's BOI requirements?
  • What are the penalties for failing to comply with the reporting requirements?

Faculty

Borchers, Cassandra
Cassandra W. Borchers

Partner
Thompson Hine

Ms. Borchers counsels clients on regulatory and compliance matters including all aspects of federal and state...  |  Read More

Snow, Elanit
Elanit Snow

Senior Counsel
Proskauer Rose

Ms. Snow represents financial institutions, hedge funds, private equity funds and multinational corporations on complex...  |  Read More

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