News’s Timely Takes Podcast Interviews Locke Lord’s Rob Evans and Ryan Last on Corporate Transparency Act’s Application to Public Companies

March 4, 2024

Rob Evans, a Partner in Locke Lord’s New York office and Chair of the Firm’s Capital Markets Practice Group, and New York Associate Ryan Last were featured on’s Timely Takes podcast. Public companies are exempt from Corporate Transparency Act (CTA) filings, but in the podcast Evans and Last explain why public company counsel should pay attention to the CTA and related Financial Crimes Enforcement Network rules. They highlight key compliance dates, activities and transactions that may have implications for public companies under the statute and actions public companies should take to ensure compliance with the statute moving forward.

Evans says, “A ‘public company’ has two meanings: To investors, managers and company counsel it means the whole business, but under the CTA only the SEC reporting company is exempt as a public company, and the CTA applies to each corporation, partnership or LLC that files documentation with a Secretary of State.”

“Public companies with wholly owned, 100%-owned direct or indirect subsidiaries are exempt,” Last adds. “This means companies should check for any joint ventures or other equity investments where the public company owns more than 25%.”

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