We are happy to announce that FinCEN Report Company has filed a patent application for our CTA Compliance Hub(TM) system.
Through our CTA Compliance Hub system, users can file beneficial ownership reports with FinCEN under the Corporate Transparency Act while maintaining the confidentiality and security of their personally identifiable information.
Individuals Maintain Confidential Data Security for their PII
Our CTA Compliance Hub system allows users to create their own secure ‘data locker’ to house their personally identifiable information (PII). Each individual’s data locker is encrypted both at rest and in transit. Individual accounts are free and an individual can edit or delete the data in their personal data locker at any time.
Individuals with personal accounts can also create company accounts for CTA reporting companies with which they are associated.
From inside the reporting company account, the reporting company may invite its beneficial owners to create their own secure personal accounts to contain their own PII.
The CTA Compliance Hub system allows the reporting company’s senior officers, board members, beneficial owners and their professional advisors to collaborate on the compliance process. Professional advisors can assist their reporting company clients on the process of determining which individuals are “beneficial owners” as defined under the Corporate Transparency Act. Through the patent-pending CTA Compliance Hub, each beneficial owner is able to keep their PII confidential and secure while simultaneously making their PII available to the company account for inclusion in the reporting company’s beneficial ownership report.
Filing the Initial Beneficial Ownership Report
Reporting companies in existence before January 1, 2024 will have until December 31, 2024 to file their initial beneficial ownership report. Many will choose to file through FinCEN Report Company’s CTA Compliance Hub system.
Reporting companies with accounts in our system will be able to file an initial beneficial ownership report electronically. The beneficial ownership report will include the required PII from each beneficial owner that the reporting company has selected for inclusion in the report, with the advice of the reporting company’s professional advisors.
All the collaborative work made possible through the CTA Compliance Hub system prior to filing an initial report is free. When the reporting company files its first beneficial ownership report, our company charges a one-year subscription fee.
The System Tracks Changes and Files Amendments
After a reporting company files its first beneficial ownership report, the reporting company must file an amendment within 30 calendar days after any change in previously-reported information, including any change in previously-reported information pertaining to one of its beneficial owners.
How are reporting companies supposed to keep track of beneficial owner data? The CTA Compliance Hub system does it for them.
When an individual beneficial owner makes any change to their previously-reported PII, the CTA Compliance Hub system notifies each reporting company that is associated with that beneficial owner. The system prompts the administrators who control the reporting company’s account of the need to file an amendment. The system makes it possible for the reporting company to file the amendment electronically with FinCEN with just a few clicks.
There is no charge for filing amendments to a beneficial ownership report. The one-year subscription fee covers the initial beneficial ownership report and an unlimited number of amendments during the subscription year.
The System Retains An Audit Trail for Due Diligence
After the Corporate Transparency Act is implemented on January 1, 2024, mergers and acquisitions (M&A) will require acquiring companies to review the CTA filing histories of target reporting companies. The CTA Compliance Hub system will help subscribing reporting companies demonstrate their compliance for due diligence purposes.
A subscribing reporting company will be able to produce a report that shows the date, time and official filing receipt for its initial beneficial ownership report, as well as an audit trail of subsequent data changes and subsequent amendments.
The CTA Compliance Hub system will add value to the due diligence process by producing a third-party report that demonstrates compliance over time.
The CTA Compliance Hub Assists Attorneys Advising Clients
The FinCEN Report Company does not provide professional services or consulting advice. Our company’s CTA Compliance Hub serves as a secure collaboration and filing system that can allow a single reporting company to interact with its beneficial owners and multiple sets of professional advisors, if desired.
As a result, we are happy to help individual lawyers, law firms, accounting firms and other professional advisors with the compliance journeys the take with their clients.
Lawyers, law firms, accounting firms and other professional advisors are able to invite their clients, both individually and in large batches, to begin their CTA compliance efforts in the CTA Compliance Hub. We can send individualized welcome letters to client representatives that give them instructions on using the system and that invite their to contact the lawyer or other advisor who invited them through our system.
About The Author
Jonathan Wilson is the co-founder of FinCEN Report Company with 31 years of experience in corporate, M&A and securities matters. He is the author of The Corporate Transparency Act Compliance Guide (to be published by Lexis Nexis in the summer of 2023) and the Lexis Practical Guidance Practice Note on the Corporate Transparency Act.
