Katie BaileyThe Financial Crimes Enforcement Network (FinCEN) has finalized changes to the Corporate Transparency Act’s (CTA) Beneficial Ownership Information (BOI) reporting requirements. The final rule, issued August 11, 2026, removes the federal BOI reporting requirement for U.S. companies and U.S. persons. The rule is effective upon publication in the Federal Register.
Under the final rule, entities created in the United States are no longer required to report BOI to FinCEN. Foreign reporting companies that remain subject to the reporting requirement are not required to report information about U.S. person beneficial owners or U.S. person company applicants. U.S. persons are also exempt from providing BOI to a reporting company for purposes of the CTA reporting requirements.
What This Means for Credit Unions
The change is important for credit unions because the elimination of the CTA reporting requirement does not eliminate applicable Bank Secrecy Act (BSA) and Customer Due Diligence (CDD) requirements.
Credit unions should continue to follow their existing requirements for identifying and verifying beneficial owners of applicable legal entity members under the CDD Rule. The information collected by a credit union for its own compliance responsibilities is separate from the information businesses were previously required to report directly to FinCEN under the CTA.
Credit unions should review account opening procedures, forms, training materials, websites, and other guidance that reference CTA BOI reporting to determine whether updates are needed. Staff should also be prepared to explain that the end of the federal BOI reporting requirement for U.S. businesses does not mean the credit union can discontinue applicable beneficial ownership identification and verification requirements.
The end of federal BOI reporting changes what U.S. businesses must report directly to FinCEN, but it does not eliminate applicable BSA and CDD requirements for credit unions. Credit unions should update previous references to CTA reporting while continuing to follow their applicable beneficial ownership procedures and risk-based CDD requirements.
