FinCEN permanently ends beneficial ownership reporting requirements for U.S. small businesses

Final rule makes March 2025 relief permanent following years of ADA advocacy 

The U.S. Department of the Treasury has finalized a rule making permanent in regulation the exemption from beneficial ownership information reporting requirements for U.S. companies, delivering the permanent relief the ADA had sought for dental practices. 

The Financial Crimes Enforcement Network, or FinCEN, announced Aug. 11 that U.S. companies will remain exempt from beneficial ownership information reporting under the Corporate Transparency Act. FinCEN also said it will remove previously submitted information about U.S. companies and U.S. persons that is no longer required. Businesses and individuals do not need to contact FinCEN to request deletion, and the agency will announce when the deletion process is complete. 

The final rule makes permanent the exemptions FinCEN first established in an interim final rule in March 2025. That interim rule had already relieved U.S.-created companies, including dental practices, of their filing obligations. The final rule will take effect upon publication in the Federal Register. 

The ADA had advocated for relief from the Corporate Transparency Act, or CTA, requirements, which would have affected many dental practices. The Association joined small business coalitions pressing Congress for relief, supported efforts to delay the filing deadline and penalties, and in December 2024 said it would continue working with Congress, its small-business partners and the incoming administration to pursue a permanent solution. 

The Corporate Transparency Act was enacted by Congress in 2021 as part of broader anti-money laundering legislation. It was intended to help combat the use of businesses for money laundering and other illicit activity by requiring certain companies to disclose information about the people who ultimately own or control them. Critics of the law argued that it imposed high front-office costs and logistical burdens on legitimate American businesses. FinCEN’s original reporting rule took effect Jan. 1, 2024. 

Under the original requirements, many dental practices would have had to report information about the practice and its beneficial owners. ADA News previously reported that dental practices were subject to the requirements if they employed fewer than 20 people or generated less than $5 million in annual gross receipts. Required information about beneficial owners included names, dates of birth, residential addresses and identifying information from a driver's license, passport or state identification card.  

 The original law also carried significant civil and criminal penalties for willful violations. In a 2024 coalition letter, the ADA and more than 120 other trade associations raised concerns about the impact of the reporting requirements on small businesses and called for temporary relief. 

“The [Corporate Transparency Act] began as an earnest attempt to combat illicit financial activity but has morphed into a bureaucratic nightmare targeted squarely at America’s smallest businesses,” according to the letter.  

For dentists, the practical takeaway is straightforward: dental practices created in the United States do not need to file beneficial ownership information reports or update or correct reports previously filed. U.S. persons who obtained FinCEN identifiers also no longer need to update or correct the information associated with them. 

Foreign entities that qualify as reporting companies will continue to have reporting obligations for non-U.S. beneficial owners and company applicants, subject to the final rule’s exemptions. FinCEN has also issued frequently asked questions and said it will update its online guidance to reflect the final rule. 

While the final rule makes the exemption permanent in federal regulation, the Corporate Transparency Act remains law and the issue could be revisited. Sens. Chuck Grassley, R-Iowa, and Sheldon Whitehouse, D-R.I., who helped develop the legislation that ultimately became the CTA, criticized the final rule Aug. 13, arguing that exempting U.S. companies undermines congressional intent. The ADA will continue to monitor congressional, regulatory and legal developments that could affect reporting requirements for dental practices and other small businesses.