The Corporate Transparency Act and Beneficial Ownership Information

Louisiana REALTORS® • December 5, 2024

The Corporate Transparency Act (made effective on January 1, 2024) expanded anti-money laundering laws and created new reporting requirements for certain companies doing business in the U.S. Beginning January 1, 2024, many small businesses are required to report information about their beneficial owners to the Financial Crimes Enforcement Network (“FinCEN”) in an effort to create a national database for use by national security and law enforcement agencies to prevent the use of shell companies for criminal activity. The new reporting requirements apply to domestic and foreign companies created or registered to do business in the U.S. by filing a document with the Secretary of State (“SOS”) or similar office. While certain types of businesses are exempt from filing (e.g. tax-exempt entities, banks and credit unions, large operating companies, inactive entities), the new rules are targeted at small businesses.


Who Must File

Both domestic and foreign reporting companies are required to file reports. A company is considered a reporting company if a document was filed with SOS or similar office to create or register the entity. Corporations (including S corporations), LLCs, and other entities formed through the SOS are subject to the reporting requirements. But, because sole proprietorships, trusts, and general partnerships do not require the filing of a formal document with the SOS, they generally are not considered a reporting company and will not have a filing requirement. Foreign companies are required to file reports if they are registered with the SOS or similar office under state law.


Some companies are exempt from reporting, but many of the exempted companies are already required to report ownership information to a governmental authority. Of particular interest to you may be the exemption for large operating companies. A large operating company is any entity with (a) more than 20 full-time US employees, (b) an operating presence at a physical office within the US, and (c) more than $5,000,000 of US-sourced gross receipts reported on its prior year federal income tax return. If you meet these qualifications, you are not subject to the new reporting requirements.


What Information Must be Provided

Beneficial ownership information (BOI) must be reported for the reporting company’s beneficial owners and (for entities formed or registered after December 31, 2023) company applicants. BOI includes an individual’s full legal name, date of birth, street address and a unique ID number. The unique ID number can be from a non-expired US passport, state driver’s license, or other government-issued ID card. If the individual does not have any of those documents, then a non-expired foreign passport can be used. An image of the document showing the unique ID number must also be included with the report.


Beneficial Owners

Two groups of individuals are considered beneficial owners of a reporting company: (1) any individual who directly or indirectly owns or controls at least 25% of the ownership interests of the reporting company; or (2) any individual who exercises “substantial control” over the reporting company.


Individuals with substantial control are those with substantial influence over important decisions about a reporting company’s business, finances, and structure. Senior officers (president, CFO, general counsel, CEO, COO, and any other officer who performs a similar function) are automatically deemed to have substantial control, as are individuals with the authority to appoint or remove senior officers and board members. There is no requirement that these individuals have actual ownership in the company to be a considered a beneficial owner for reporting purposes.


Company Applicants

The company applicant is the person who actually files the document that creates or registers the reporting company (e.g., an attorney). Company applicants must provide the same information that is required of beneficial owners, but only if the reporting company is formed or registered after December 31, 2023. Because of the difficulty in tracking down information about company applicants for reporting companies that have been in existence for a number of years, reporting companies formed or registered before January 1, 2024 do not have to supply BOI for their company applicants.


FinCEN Identifiers

Individuals and reporting companies can request a FinCEN Identifier (FinCEN ID) to use in place of supplying detailed information on the report. A FinCEN ID is a unique number assigned by FinCEN which is obtained by submitting the same information as is required of a beneficial owner or reporting company. A FinCEN ID may be useful to individuals that prefer to send their personal information directly to FinCEN rather than through a reporting company, or to individuals that may be required to supply information as a beneficial owner or company applicant of several reporting companies.


Important Filing Dates

For existing reporting companies created or registered before January 1, 2024, the initial report is due by January 1, 2025. For reporting companies created or registered on or after January 1, 2024, the initial report is due 90 days after the entity’s creation or registration. For reporting companies created or registered after January 1, 2025, the initial report is due 30 days after the entity’s creation or registration.


If there is a change to previously reported information about the reporting company or its beneficial owners, an updated report must be filed within 30 days of the change. So, it is imperative that your company implement a system to identify reportable changes and file an updated report with FinCEN in a timely manner. The penalties for willfully failing to file both initial and updated reports are $500 per day that the report is late, up to $10,000, and imprisonment for up to two years.


How to File

BOI reports must be filed electronically. FinCEN’s e-filing portal, available at https://boiefiling.fincen.gov/, provides two methods to submit a report: (1) by filling out a web-based version of the form and submitting it online, or (2) by uploading a completed PDF version of the BOI report. Some third-party service providers may also offer the ability to file the BOI report through their software. The person who submits the BOI report will need to provide their name and email address to FinCEN. There is no fee for filing the report.

2026 Legislative Session Scoop - Week 7 Recap

By Louisiana REALTORS® • April 24, 2026
Week seven of the 2026 Regular Session was one of the most active weeks yet for legislation affecting the real estate industry. Louisiana REALTORS® remained heavily engaged as lawmakers advanced bills dealing with property disclosures, appraiser liability, rent regulation, insurance, blight, redevelopment and other issues that directly affect real estate professionals, property owners and consumers across the state. One of the most important bills this week was HB 1166 by Rep. Kim Carver , which would require disclosures for vacant residential property. The bill was reported from House Commerce with amendments on a 14-0 vote and then amended on the House floor, ordered engrossed, and passed to third reading. Louisiana REALTORS® testified on the bill in committee and worked closely with the author to better posture the legislation. Amendments advanced by our team were accepted by the author, helping improve the bill while preserving a practical disclosure framework that increases transparency without creating unnecessary confusion in the transaction process. Another closely watched issue this week was consumer-fee disclosure legislation. HB 617 by Rep. Mandie Landry moved this week, advancing from House Commerce and then the House floor, while HB 580 , another hidden-fee disclosure bill touching real estate transactions, remains pending. Louisiana REALTORS® is opposed to these measures in their current form to the extent they apply to real estate professionals because they are not well-tailored to the realities of real estate transactions, where many costs are negotiated, variable or controlled by third parties. Louisiana REALTORS® testified in opposition to the bills we oppose and is actively working with the author to better posture the legislation and remove real estate professionals from its scope altogether. On HB 472 by Rep. Alonzo Knox , the rent stabilization bill, the author is expected to try to bring the measure back before the committee next week with amendments. Even so, Louisiana REALTORS® remain opposed to the bill on principle. Price gouging is already illegal under existing law, and government-imposed rent regulation is not the right answer to housing affordability challenges. Louisiana REALTORS® testified in opposition to the bill and continues to oppose the measure because policies like this risk discouraging investment, reducing housing supply, and creating further market distortions rather than solving the underlying problem. HB 468 by Rep. Troy Hebert , which regulates the wholesale of residential real property, remains pending in the Senate Commerce Committee and continues to be an important bill for the industry. Likewise, HB 1027 by Rep. Troy Hebert , dealing with appraiser liability, had a strong week, passing the House 90-0 and moving to the Senate. Both measures are significant because they promote greater clarity, consumer protection and confidence in the real estate marketplace. Blight and redevelopment issues also remained active. HB 284 by Rep. John Wyble , which would allow certain local governments to expropriate blighted property through a declaration-of-taking process, remains subject to call and continues to raise serious concerns about private property rights. By contrast, HB 214 and HB 217 by Rep. Chance Henry , which create tax incentives for the rehabilitation of blighted property, represent a more constructive redevelopment approach by encouraging reinvestment rather than expanding government taking authority. Insurance legislation also remained a major focus this week, with multiple bills heard that could affect homeownership costs, market stability and post-storm recovery. Measures dealing with Louisiana Citizens assessments, pre-suit insurance claim review, the Fortified Homes Program and insurance market transparency all carry real implications for affordability and transaction viability. In Louisiana, insurance remains one of the most important issues affecting the real estate market, and Louisiana REALTORS® continues to closely track that legislation. Taken together, week seven showed that Louisiana REALTORS® remains actively engaged where it matters most: supporting practical transaction standards, protecting private property rights, testifying for and against legislation when necessary, pushing back on unworkable regulation and rent-control-style policies, and advancing policies that strengthen housing opportunity and market stability across Louisiana. Please view the weekly bill tracking report provided by our lobbying team over at Harris, DeVille and Associates.

Consumer Guide Update: Navigating Interest Rates Shifts

By Louisiana REALTORS® • April 23, 2026
NAR is pleased to share the latest consumer guide helping buyers navigate shifting interest rates. The one-page guide covers how lenders set rates, the impact of small shifts on monthly payments and strategies to get the lowest rate possible. As a reminder, all guides in this series are available for download—in both English and Spanish—on facts.realtor . Please allow up to two weeks for the Spanish version of the latest resource to be translated and uploaded. For ease of reference, below is a list of the most recent guides: NEW: Navigating Interest Rate Shifts Financing a Renovation When You Buy Staging Your House for a Sale Spotting Deepfake Scams in Real Estate Are You Ready to Invest in Real Estate? Thank you for your continued engagement with the “Consumer Guide” series and for sharing the resources with prospective clients to ensure they have the information they need to find success in their home buying or selling journey. Remember that these guides are for informational purposes only and are not meant to enact or change any existing NAR policy. Be on the lookout for the next consumer guide, which looks at how solar installations may impact home sales transactions.

2026 Legislative Session Scoop - Week 6 Recap

By Louisiana REALTORS® • April 17, 2026
Louisiana REALTORS® spent week six of the Legislative Session actively engaged on several bills at the Capitol impacting core industry priorities, including private property rights, affordability, redevelopment and transaction-related regulations. Most of the meaningful activity remained in the House, where lawmakers continued advancing measures with direct implications for the real estate market. HB 284 by Rep. John Wyble , which would authorize certain local governments to expropriate blighted property by declaration-of-taking, failed on final passage in the House Tuesday by a 48-47 vote, and remains subject to reconsideration. Meanwhile, HB 472 by Rep. Alonzo Knox , which would authorize rent stabilization at the local level, was voluntarily deferred in committee following testimony from Louisiana REALTORS® and our partners at the Louisiana Apartment Association effectively ending its path this session. This marks a significant win, as rent control policies do not address housing supply challenges and instead risk further market distortion. In House Commerce, several key bills moved forward. HB 1027 by Rep. Troy Hebert , which clarifies that appraisers are not liable for a seller’s failure to meet smoke and carbon monoxide detector requirements, passed committee unanimously and is now slated for a House floor vote. This common-sense measure protects appraisers and helps preserve efficiency in the transaction process. HB 673 by Rep. Tammy Phelps , which would have imposed new security camera mandates on certain blighted properties, was also voluntarily deferred following industry opposition. Additionally, HB 426 by Rep. Phelps , which addresses criminal blighting and expands enforcement liability, remains under consideration. Louisiana REALTORS® is monitoring this bill closely to ensure efforts to address blight do not unintentionally discourage investment or redevelopment. We continue to track broader market integrity and redevelopment efforts. HB 468 by Rep. Hebert , addressing residential wholesaling, has now moved to the Senate after unanimous House passage. HB 217 by Rep. Chance Henry , which provides tax incentives for the rehabilitation of blighted property, also remains active in the Senate and represents a constructive approach to redevelopment. Looking ahead, the House Commerce Committee will consider HB 1166 by Rep. Kim Carver next week, which addresses disclosure requirements for vacant residential property. Louisiana REALTORS® supports clear, consistent consumer disclosures and have been working closely with the author and the Louisiana Real Estate Commission to ensure the bill is structured to promote transparency while maintaining practical standards and avoiding unintended liability for real estate professionals. Overall, the House carried the bulk of real estate activity this week, while the Senate saw limited movement on major REALTOR® priorities. As the session continues, Louisiana REALTORS® remains focused on protecting private property rights, opposing harmful market interventions, supporting responsible redevelopment and advancing policies that strengthen real estate transactions for both consumers and our members. Please view the weekly bill tracking report provided by our lobbying team over at Harris, DeVille and Associates.
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