During the height of the COVID-19 pandemic, the Small Business Administration (SBA) launched various loan programs, such as the Paycheck Protection Program (PPP) and the Economic Injury Disaster Loan (EIDL) program, to support businesses grappling with unprecedented economic challenges. These programs were lifelines for many, providing essential funds to keep businesses afloat. However, as we move forward, the SBA has started to collect on these loans, leading to new challenges and questions for borrowers.

As a transactional attorney, I focus my practice on helping clients plan for and react to business events much more so than I do on interpreting statutes or legislation. Sometimes, however, a statutory change or judicial ruling will have a wide-ranging—and retroactive—impact that is impossible to ignore.

As previously posted by Jonathan Milgrom, the Corporate Transparency Act (CTA) went into effect when the clock struck midnight on January 1, 2024. This transformative piece of legislation, will reshape the corporate landscape,ushering in a new era of transparency and accountability. This landmark legislation marks a significant step forward in the fight against financial crime and anonymous corporate activities. The central tenet of the CTA is to enhance corporate transparency by requiring companies to disclose their beneficial ownership information to the Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Department of the Treasury.