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On April 5, 2021, FinCEN issued an Advance Notice of Proposed Rulemaking (ANPRM) entitled "Beneficial Ownership Information Reporting Requirements,” relating to the Corporate Transparency Act (Sections 6401 - 6403 of the Anti-Money Laundering Act of 2020 (the AML Act)), and intends to issue a Notice of Proposed Rulemaking.  Section 6403 amends the Bank Secrecy Act by adding new Section 5336 to title 31 of the United States Code.  New Section 5336 requires FinCEN to issue rules requiring: (i) reporting companies to submit certain information about the individuals who are beneficial owners of those entities and the individuals who formed or registered those entities; (ii) establishing a mechanism for issuing FinCEN identifiers to entities and individuals that request them; (iii) requiring FinCEN to maintain the information in a confidential, secure non-public database; and (iv) authorizing FinCEN to disclose the information to certain government agencies and financial institutions for purposes specified in the legislation and subject to protocols to protect the confidentiality of the information. Section 5336 requires that the first of these requirements, notably the beneficial ownership information reporting regulation for legal entities (the "reporting regulation”), be published in final form by January 1, 2022.  The ANPRM solicited comments on a wide range of questions having to do with the possible shape of the reporting regulation, as well as questions that concern the interaction of the requirements of this regulation and the shape and functionality of the database that will be populated with the information reported under Section 5336.