Resources

Client Alerts, News Articles, Blog Posts, & Multimedia

Everything you need to know about BMD and the industry.

SMALL BUSINESS ALERT: January 1, 2024 - Beneficial Ownership Information Reporting

Client Alert
October 13, 2023

Beginning on January 1, 2024, many small businesses across the United States will have to report personal information about their owners, beneficial owners, and others who own or exercise control over the company. The information will have to be reported to, and maintained by, the Financial Crimes Enforcement Network (“FinCEN”) as part of the Beneficial Ownership Information Rule. FinCEN is a bureau of the U.S. Department of the Treasury.

The Rule was adopted as part of the Corporate Transparency Act passed by Congress in 2021. The required reporting is designed to make it more difficult for bad actors to shelter or hide finances through shell companies or complicated ownership structures. All domestic and foreign corporations, LLC’s, or other entities created by the filing of a document with the Secretary of State or similar office in the United States must file, unless it qualifies for one of the several enumerated exemptions identified in the Rule.  A business required to file (a “reporting company”) will need to include certain specified personal information concerning:

  • The business itself.
  • Any owners holding 25% or more of the stock, voting rights, or ownership interests in the company.
  • Any other individuals (such as senior officers or other important decision makers), whether or not they are owners, who exercise substantial control over the company’s finances, structure, or business operations.
  • Individuals who filed, or directed the filing, of the organizing documents that created or registered the company (for entities formed after 1/1/2024).

The personal information for any individual required to be disclosed includes the individuals full name and address, date of birth, and other identifying information such as a passport number, driver’s license number, etc.

Because the intent of the legislation is to gain information from small businesses, those businesses existing on January 1, 2024 will have one (1) year to comply. Any businesses formed after January 1, 2024 will need to disclose and file the beneficial owner information within thirty (30) days of the entities formation. In addition, any changes in the information disclosed must be updated within thirty (30) days.

A failure to report complete or updated information to FinCEN, or an attempt to provide false or fraudulent information, may result in civil penalties of up to $500 for each day that the violation continues, or criminal penalties including imprisonment for up to two (2) years and/or a fine of up to $10,000. Senior officers of an entity that fails to file a required report may be held accountable for that failure.

Business owners should act now to 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 Rule. For more information about The Rule or how to comply, please contact BMD Member Blake Gerney at brgerney@bmdllc.com. 

small businessBlake R. GerneyBeneficial Ownership Information Reportingbusiness and corporate law
Client Alert

Update on Temporary Protected Status (TPS) for Haiti and Related Countries

July 13, 2026USCIS has temporarily extended Employment Authorization Documents (EADs) for certain Temporary Protected Status (TPS) beneficiaries from Haiti and several other countries following recent court action. Employers and TPS recipients should review EAD expiration dates, monitor ongoing developments, and ensure compliance with Form I-9 and E-Verify requirements.Client Alert

HHS Accessibility Requirements for Medical Diagnostic Equipment: What Health Care Providers Need to Know

July 8, 2026Health care providers that receive federal financial assistance are now subject to updated HHS accessibility requirements for medical diagnostic equipment under Section 504 of the Rehabilitation Act. With the July 8, 2026, compliance deadline in effect, covered providers should ensure they have the required accessible equipment, train staff, and review operational practices to reduce compliance risk and provide accessible care for patients with disabilities.Client Alert

Florida Super Lawyers® Recognizes Brennan Manna Diamond Attorneys to the 2026 Lists

June 26, 2026BRENNAN, MANNA & DIAMOND is proud to announce that three of our attorneys have been designated to the 2026 Florida Super Lawyers® and Florida Rising Stars® lists. Super Lawyers is based on multiple categories of independent research and peer evaluation to identify outstanding lawyers.Client Alert

Supreme Court Clears Path for TPS Terminations: What Employers Need to Know

June 25, 2026The U.S. Supreme Court's June 25, 2026 decision in Mullin v. Doe and Trump v. Miot removed legal obstacles that had delayed the termination of Temporary Protected Status (TPS) for Haiti and Syria. The ruling also reinforces the administration's authority to terminate other TPS designations currently under review. Employers should immediately identify workers whose employment authorization is tied to affected TPS programs, review Form I-9 records, and prepare for forthcoming USCIS guidance before taking any employment action.Client Alert

The Risks of Outsourcing Medical Billing and the Importance of State-Law Compliance

June 24, 2026Offshoring medical billing and other administrative functions can reduce costs, but it also raises significant compliance, operational, and contractual risks. Although HIPAA does not explicitly prohibit protected health information from being accessed or stored outside the United States, healthcare providers and their vendors remain responsible for safeguarding patient information and complying with state-specific restrictions that may limit or prohibit offshore subcontracting.
Older posts