Corporate Transparency Act
The Corporate Transparency Act/BOI Reporting Requirements back in effect
Beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA) are once again back in effect following the February 18, 2025 decision of the U.S. District Court for the Eastern District of Texas in Simth, et al. v. U.S. Department of Treasury et al.
The new deadline to file an initial, updated and/or corrected BOI report is now March 21, 2025. Companies that have already filed a BOI report do not need to take any additional steps at this time. Moving forward, new companies formed after February 19, 2025 will have 30 days to file their initial report.
FinCEN has indicated that between now and March 21, 2025 it will “asses its options to further modify deadlines, while prioritizing reporting for those entities what post the most significant national security risks. FinCEN also intends to initiate a process this year to reduce [the] burden for lower-risk entities, including many U.S. small businesses.”
In addition, a bill was passed unanimously by the U.S. House of Representatives and is now before the U.S. Senate which would extend the deadline to report to January 1, 2026 for entities created before January 1, 2024. A separate bill introduced in the U.S. Senate would completely repeal the CTA. There also remain a number of ongoing court challenges throughout the United Sates.
As with past developments, the future of the CTA remains uncertain, and possible Congressional and/or court actions could delay, change or eliminate BOI reporting requirements. Clients are urged to closely monitor developments to the CTA and the FinCEN website for additional guidance.
CMP is pleased to help clients navigate the CTA requirements and assist with filing your BOI report. Please reach out to our corporate transactional attorneys if you would like our assistance.
Jim Schriemer at Schriemer@cmplaw.com
Marjorie Dixon at Dixon@cmplaw.com
Chris Wallaker at Wallaker@cmplaw.com
Albert Balewski at Balewski@cmplaw.com