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Corporate Transparency Act: Business Owners Must Act Now

Client Alert

The Corporate Transparency Act (CTA) has been in effect since January 1, 2024. It is vital for reporting companies to file their beneficial ownership information (BOI) report before the year ends. Reporting companies formed prior to January 1, 2024, have less than six (6) months left to file. It is important to act now in order to avoid facing steep penalties for failing to comply with the CTA. Business owners should identify whether their company must report and if so, which individuals within the business entity are required to disclose the personal information designated under the CTA.

The CTA requires reporting companies to file a BOI report. Reporting companies must provide information regarding their entity, beneficial owners, and in some cases, the professional advisor(s) that helped form the entity. Reporting companies must submit the information to the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN). Domestic reporting companies include corporations, LLPs, LLCs, and other similar entities that were formed through a filing with the secretary of state or similar office under the law of a state. Foreign reporting companies are those formed under the law of another country and are registered to do business in any U.S. state through filing with a secretary of state or any similar office under the law of a state.

Under the CTA, reporting companies that were formed prior to January 1, 2024, have one (1) year to comply and file their beneficial ownership information report. Reporting companies formed in 2024, must file their report within ninety (90) days of their formation. Reporting companies formed on or after January 1, 2025, will have only thirty (30) days to file their report following their formation.

The purpose of the CTA is to safeguard the U.S. financial system from fraud, money laundering, and other illegal activities. There has been a concern in recent years that the U.S. has become a jurisdiction of choice for bad actors to create shell companies that hide the ultimate beneficiaries. Through the CTA, a national registry will be created that will allow the U.S. to obtain all relevant ownership information regarding reporting companies. The registry will enable the U.S. to crack down on illegal activity such as tax fraud, money laundering, terrorist financing, and more.

There are harsh penalties for reporting companies that fail to file a timely report to FinCEN. Civil and criminal penalties may result in fines up to $10,000, imprisonment for up to two (2) years, or both. Any person who (i) willfully provides or attempts to provide false/fraudulent information, or (ii) fails to report and/or update a report previously made, may be subject to the aforementioned penalties.

For more information about the CTA or how to comply, please contact BMD Member Blake Gerney at brgerney@bmdllc.com.


Supreme Court Upholds Coverage under the Affordable Care Act

The U.S. Supreme Court has upheld the authority of the U.S. Preventive Services Task Force under the ACA, ensuring continued no-cost coverage for over 100 preventive health services. The decision impacts millions of Americans and preserves provider reimbursement through insurance.

Health Care Providers Take Note: Federal Budget Brings Medicaid and Staffing Rule Changes

The 2025 federal budget introduces significant changes for health care providers and Medicaid recipients, including new cost-sharing requirements, work eligibility mandates, rural health grants, and a pause on minimum staffing rules.

Key Healthcare Provisions in Ohio’s 2026–2027 Budget

Ohio’s newly enacted biennial budget (HB 96) for FY 2026–2027 brings sweeping changes for healthcare providers across the state. The law includes new Medicaid eligibility requirements, reporting mandates, funding directives, and social policy provisions. Several vetoes by Governor DeWine also affect healthcare-related initiatives.

Providers Beware: Court Sides with Insurers in No Surprises Act Arbitration

On June 12, 2025, the Fifth Circuit ruled in favor of Aetna and Kaiser in two lawsuits brought by air ambulance providers challenging how insurers calculated payments under the No Surprises Act’s Independent Dispute Resolution process. The court held that unless there is clear evidence of fraud or serious misconduct, IDR decisions will stand, reinforcing the finality of the arbitration process.

Introducing HB 281: Enforcement of Federal Immigration Laws in Ohio Hospitals

House Bill 281, introduced on May 20, 2025, would require Ohio hospitals to allow law enforcement, including federal immigration agents, to enter facilities and enforce immigration laws. The bill mandates that hospitals comply with information requests and adopt formal policies, raising significant concerns about patient privacy and access to care for immigrant communities.