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Corporate Transparency Act Reporting Deadline: December 31

Client Alert

The Corporate Transparency Act (“CTA”), which became effective January 1, 2024, imposes strict reporting guidelines on small business owners throughout the country. The deadline for non-exempt businesses to submit reporting is December 31, 2024.

The civil penalty for failing to file reporting required under the CTA if $591 per day, up to a total of $10,000. Also note that criminal penalties are authorized for any person who willfully (i) provides or attempts to provide false/fraudulent information or (ii) fails to report and/or update a report previously made.

If you are the beneficial owner of an entity formed pursuant to a filing with a state secretary of state’s office (i.e., an LLC or a corporation), your entity must report. There are a few exemptions to this reporting requirement. If an entity meets an exemption, it does not need to presently report.  However, if an exemption ever becomes inapplicable to the entity, the entity then has 30 days to report. 

Completed reports are not public record; reporting is maintained by the financial crimes wing of the Department of the Treasury in a database that’s only accessible by state and federal law enforcement.

To avoid facing a potential steep fine to kick of your 2025 fiscal year, or to better understand whether your entity needs to report, please do not hesitate to contact BMD Attorney Jacob R. Davis (jrdavis@bmdllc.com).

For a more detailed overview on the CTA, click here.


Unveiling Ohio's Pharmacy Board Updates for Distributors, Mobile Clinics, and Controlled Substances

The Ohio Board of Pharmacy will hold a public hearing on May 28, 2024, to discuss several proposed changes and additions to Ohio Administrative Code (OAC). These changes pertain to terminal distributors of dangerous drugs (TDDDs), mobile clinics or medication units, and the classification of controlled substances.

House Bill 249: Key Updates to Involuntary Hospitalization Law for Mental Health Providers

House Bill 249 (HB 249) proposes changes to Ohio Revised Code (ORC) Sections 5122.01 and 5122.10 to expand the conditions under which a person with a mental illness can be involuntarily hospitalized.

Starting an Advanced Practice Provider Practice

Advanced practice providers (APPs), which includes non-physician providers such as nurse practitioners, physician assistants, and nurse anesthetists, commonly start their own healthcare practices. Practices may provide, for example, service offerings such as primary care, anesthesiology, mental health, and aesthetics (medical spas). However, there are a number of considerations and steps that must be taken for APPs to compliantly function independently.

FTC Increases Targeting of Companies Lacking Cyber Protection

The Federal Trade Commission (FTC) recently released a comprehensive cybersecurity report outlining key findings and recommendations based on emerging threats, trends in data breaches, and strategies for businesses to enhance their cybersecurity posture observed over the last year.

New Federal Medical Conscience Rule and Its Implications

The Department of Health and Human Services Office for Civil Rights issued a Final Rule to clarify protections for healthcare providers who refuse services based on religious or moral beliefs. This includes protection against discrimination for refusing procedures like assisted suicide or abortion. The OCR can receive complaints, conduct investigations, and enforce these protections. Entities are encouraged to update policies accordingly and display a model notice provided by the OCR.