Corporate Transparency Act and Healthcare Entities: Reporting Companies, Exemptions, Beneficial Ownership Reporting

Description

The CTA, which went into effect on Jan. 1, 2024, requires certain U.S. and foreign entities defined as "reporting companies" to report certain identifying information about themselves, their beneficial owners, and company applicants to FinCEN (the U.S. Dept. of the Treasury's Financial Crimes Enforcement Network) within a certain prescribed time period.

Failure to comply with the new reporting requirements could result in civil and criminal penalties. The CTA imposes a civil penalty of not more than $500 for each day that there is a willful failure to report complete beneficial ownership information or a willful provision of or willful attempt to provide false or fraudulent beneficial ownership information. Further, a person may face a fine of up to $10,000 and imprisonment.

The CTA includes several exemptions, which may mean some larger healthcare entities will not have to meet the reporting requirements. However, smaller healthcare entities are not likely to be exempt. Therefore, they must understand and comply with the new requirements. Smaller healthcare entities are not alone. MSOs that are owned in part by private equity and some joint venture arrangements may be required to report.

Listen as our authoritative panel of healthcare attorneys examines the implications of the CTA for healthcare. The panel will provide an overview of the CTA and will discuss how the new CTA requirements apply to and/or impact physician groups, physician-hospital joint ventures and other joint venture arrangements as reporting companies, and MSOs co-owned by private equity firms. The panel will discuss who needs to be named as a beneficial owner and offer best practices for meeting CTA requirements.