Bruce Mills

Washington, DC, Nov. 26, 2024 Today, the PCAOB posted additional resources related to the implementation of QC 1000, A Firm’s System of Quality Control.   QC 1000 Staff Guidance – All firms registered with the PCAOB, including those that do not audit issuers or SEC-registered brokers and dealers, are affected by QC 1000, but not all requirements of QC 1000 apply to every firm. This publication provides an overview of the requirements of QC 1000 and staff guidance for firms about how to comply with the standard.

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New Corportate Transparency Act deadlines for Small-Business owners who were NOT part of NSBA on or before March 1, 2024, detailed below from Forbes’ Kelly Phillips Erb. While the nationwide injunction over the CTA has been rescinded, NSBA’s separate case over this unconstitutional law remains pending, with the original exemption for certain NSBA members still in place. Follow us as we continue closely tracking this important matter that carries significant fines and includes the possibility of prison time. As significant as these penalties are, even with the short deadline extension, there should not be so much chaos coming from the administrating agencies of the CTA - still causing confusion regarding compliance among the Small-Business community.

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📢 Important Update for Business Owners! New Federal Reporting Requirements 📢 Starting January 1, 2024, many U.S. companies must comply with the Beneficial Ownership Information (BOI) requirements enforced by the U.S. Treasury's FinCEN. If your business is affected, ensure you report details about individuals who own or control 25% or more of your company. 📅 Deadline: Submit your BOI report by December 31, 2024 to avoid penalties! For more information, visit www.fincen.gov/boi, consult your CPA, or stop by your local GBT branch for assistance. #FinCen #BOI #Compliance #BusinessUpdate #Regulations #BeneficialOwnership #GBTBank

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CTA Update: Beneficial Ownership Information Reports Once Again Voluntary Reporting companies are not currently required to file Beneficial Ownership Information Reports (BOIRs) with FinCEN. This update follows a December 26, 2024, order from the 5th Circuit Court of Appeals, which reinstated a nationwide injunction against enforcement of the Corporate Transparency Act. The injunction was originally issued on December 3, 2024, but it was vacated by the 5th Circuit Court of Appeals on December 23, 2024. The underlying case seeking to declare BOIR filings unconstitutional remains pending. FinCEN will continue accepting voluntarily filed BOIRs while the injunction remains in force. Given the recent back-and-forth rulings, reporting companies that may have a reporting obligation should monitor the situation closely. Reporting companies that decide to not file while the injunction is in place should collect the necessary beneficial ownership information and be prepared to file on short notice in the event the injunction is lifted. #FinCEN #capitalengine #BOI #CTA #nationallawreview

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Registered Investment Advisers and Exempt Reporting Advisers would be required to establish, document and maintain robust Customer Identification Programs (CIPs) under proposed rulemaking from the SEC and FinCEN. On May 13, the two regulators released a joint notice of proposed rulemaking, which could significantly impact RIAs and ERAs: ◼ This would be consistent with the CIP requirements placed on other institutions, such as brokers or dealers in securities, open-end investment companies (e.g., mutual funds), credit unions, banks and other financial institutions (including RIAs or ERAs that are jointly registered or affiliated with other financial institutions). ◼ There is a 60-day public comment period and six-month deadline to comply if the final rule is adopted. ◼ This proposed rulemaking follows on the heels of a February 2024 FinCEN proposal that would subject RIAs and ERAs to anti-money laundering/countering the financing of terrorism program requirements under the Bank Secrecy Act.   Read our full alert below, including insights on the specific definitions of “customer” and “financial institution” and the geopolitical considerations of the proposed rule, from the Akin team: Brian Daly, Nnedi Ifudu Nweke, James Munsell, Barbara Niederkofler, Andrew Schlossberg https://bit.ly/4biOng7 #InvestmentManagement #SEC #FinCEN #NPRM #Compliance #FundsLitigation #Funds #AML

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Benchmarking your audit plans has never been easier! 💪 JW's "annual report helps me ensure that I don't overlook anything in my audit planning & risk assessment" -- CAE at publicly traded healthcare company 🏥

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On Aug. 12, 2024, the CRA released proposed technical amendments to the trust reporting legislation (August Draft Legislation) to narrow the scope of the trusts required to file a T3 return. Read more here: https://lnkd.in/gHw3hbBe #trustreporting

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This week's blog, the fourth in my six part series on the state of fraud in 2024, focuses on corruption - the most pervasive form of fraud: https://lnkd.in/e4secwgY

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Section 1071 Coverage Flowchart When it comes to Regulation B’s Section 1071 Rule (1071), knowing whether an application is reportable or not is critical. If you report applications that you shouldn’t or don’t report applications that you should, you will quickly find yourself in hot water with examiners. We are always looking for ways to make compliance easier and have developed a flowchart that can help! Our “Section 1071 Small Business Lending Application Coverage Flowchart (Version 1.1)” is now available in the Free Lending Tools on our website. https://lnkd.in/ekPvmQT **** Use search bar to find the correct tool. Put "1071" and search for the related tools. Jerod Moyer explains the flowchart more here: https://lnkd.in/gytQp42k Stay tuned as we have more Section 1071 tools in process! Wherever you’re at in your 1071 journey, we are here help. A good place to start is our Small Business Lending Data Collection Page, for all things 1071. We have a 1071 Implementation Group that meets monthly and, right now, there are still some spots available! We currently have several webinars focused on specific aspects of the Section 1071 requirements that are available now OnDemand and you won’t want to miss our upcoming three-part series, “ECOA (Section 1071) Small Business Lending Data Collection” beginning on August 1st. Register here - https://lnkd.in/gDQuV7yi Featured topics will include: • Rule Coverage, Mandatory Compliance Dates & Implementation Runways • How to Count Originations for Your Financial Institution • Covered Applications: What’s In and What’s Out? • Gross Annual Revenues and Small Businesses • Required Data & The Data Collection Process (Time & Manner) • Restricted Data: Business Ownership Status & Demographic Information • The “Firewall” and Recordkeeping Requirements • Your Questions, Plain English Answers & Much More https://bit.ly/3xXh5Vn

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#CBP released their August 2024 update, including a big increase in number of audits performed compared to July! See full report here: https://lnkd.in/eY6gW58Q #Quickcode #TradeCompliance

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The Jan. 1, 2025 reporting deadline for certain corporations, limited liability companies and similar entities to file beneficial ownership information under the Corporate Transparency Act (CTA) has been delayed by a court order. https://lnkd.in/g6C3ZVqP

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New York's LLC Transparency Act mandates annual beneficial ownership filings starting in 2026, aligning with the federal Corporate Transparency Act guidelines. Learn more about this state requirement plus new guidance from FinCEN on BOI reporting. Listen now: https://ow.ly/r6Ym50Tl7nR #NYCbusiness #LLCtransparency #BOIreporting #FinCENguidance #complianceupdate #corporatetransparency

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Is your bank poised to meet initial FDICIA compliance requirements? 🏛️ If you have an in-house internal audit function and/or risk management team, they could spend 600+ hours preparing for FDICIA—can their workload accommodate these increased responsibilities? ​ ​ CBIZ Risk & Advisory Services can help your internal teams focus on their priorities while providing you with FDICIA compliance guidance and best practices. Learn more here: https://okt.to/koBJRn #FDICIA #riskadvisory #compliance #ComplianceSpecialists

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Register for our webcast discussing 2024 Revisions to OMB Uniform Guidance. https://lnkd.in/g8N_Qqhh Anita Shah and Matthew Dinsdale share tips on how to prepare for and make the most of higher thresholds and reduced complexity in grant management. #mossadams #omb #notforprofits #nonprofits #highereducation #singleaudits #federalregulations #uniformgudiance

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Beneficial ownership information (BOI) reporting continues to present challenges. To help you navigate the latest developments, AICPA® membership provides exclusive access to insights and tools. https://bit.ly/3BeLj7A

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