Skip to main content

Jurisdictional Updates 12-16-21

Federal Beneficial Ownership Disclosure Reporting Delayed

The implementation of the Beneficial Ownership disclosure reporting under the Corporate Transparency Act has been delayed by the Financial Crimes Enforcement Network (FinCEN) which on December 7 issued a 188-page Notice of Proposed Rulemaking (NPRM). The comment period for the NPRM is 60 days until February 7, 2022. FinCEN also will engage in additional rulemaking to establish who may access the Beneficial Ownership Information and safeguards to secure and protect this information. More information is available at these links to the FinCEN website  Fact Sheet: Beneficial Ownership Information Reporting Notice of Proposed Rulemaking (NPRM) |  and Federal Register :: Beneficial Ownership Information Reporting Requirements.  The Secretary of State filing offices in each state have not yet revised formation filing documents or requirements based on the proposed FinCEN rules.  CSC continues to monitor this and will provide updates to customers as soon as available.  

Arkansas – LLC’s Formed Between July 27 and September 1 Remain Effective

Senate Bill 4 b (Act 7) and House Bill 1004 b (Act 12) signed by the governor and effective December 9 clarified that LLCs formed or registered between July 27 and September 1 remain in full force and effect despite the inadvertent repeal of the Small Business Entity Tax Pass Through Act effective July 27 instead of September 1, the effective date of the Uniform LLC Act. The bill text for Act 4 can be accessed at Bill Drafting Template ( and the text for Act 12 at Bill Drafting Template (