CTA is now Enforceable; FinCEN Extends Reporting Deadline
On February 18, 2025, the U.S. District Court for the Eastern District of Texas issued a stay of its January decision in Smith, et al. v. U.S. Department of Treasury, et al., which enjoined enforcement of the Corporate Transparency Act (“CTA”). As a result, there are now no court orders barring enforcement of the CTA by the Financial Crimes Enforcement Network (FinCEN), and the beneficial ownership information (BOI) reporting requirements of the CTA are again in effect.
FinCEN issued guidance on February 19, 2025, indicating that given “reporting companies may need additional time to comply with their BOI reporting obligations, FinCEN is generally extending the deadline 30 calendar days from February 19, 2025, for most companies.”
FinCEN also committed to assess its options to “further modify deadlines, while prioritizing reporting for those entities that post the most significant national security risks” and “revise the BOI reporting rule to reduce the burden for lower-risk entities, including many U.S. small businesses.”
For those reporting companies who have not already filed their BOI Reports, we recommend that you file no later than March 21, 2025. FinCEN may issue additional guidance prior to that date, so stay tuned for further updates.
Meanwhile, efforts are underway in Congress to repeal the CTA and/or extend the filing deadlines. We will continue to monitor these developments and provide updates as they occur.
Information on the CTA reporting requirements can be found at https://www.fincen.gov/boi. Please feel free to contact us if you would like assistance in evaluating your company’s CTA compliance requirements.
The information in this article is informational in nature and should not be taken as formal legal advice. You should consult an attorney for advice regarding your individual situation.
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