Mark your calendars. After months of legal back and forth, the Corporate Transparency Act (“CTA”) reporting requirements are back in effect, for now, with a new deadline of March 21, 2025.
The U.S. District Court for the Eastern District of Texas lifted its nationwide preliminary injunction, aligning with the Supreme Court of the United States’ decision earlier this year to stay a similar nationwide injunction. Consequently, reporting obligations are back on and FinCEN has extended the filing deadline to March 21, 2025.
Action Steps:
✅ Assess Your Status and Compile Ownership and Control Information: Assess if your entity qualifies as a “reporting company” under the CTA and gather the most up to date ownership and control information for your entity.
✅ Obtain FinCEN IDs or Identifying Information: Collect identifying information for each person who qualifies as a “beneficial owner” under the CTA. Encourage beneficial owners to secure a FinCEN ID to streamline reporting.
✅ Prepare for Submission: Be ready to file initial, updated, or corrected Beneficial Ownership Information (BOI) reports by the March 21 deadline using FinCEN’s E-Filing system.
✅ Stay Informed: Monitor ongoing federal litigation and potential legislative changes affecting CTA requirements.
FinCEN acknowledges that reporting companies may need additional time to meet the March 21 deadline and has stated that if it opts to modify the deadline, an update will be shared before that date. Additionally, in the coming months, FinCEN intends to revise reporting rules to reduce burdens for low-risk entities, including U.S. small businesses, while focusing on entities posing greater national security risks. This may include developing additional reporting exemptions.
Our CTA team will keep you updated on the latest developments. To read the full Client Alert, visit here.
For more information on our CTA team, visit their bios here:
Lorren Patterson
Paul-Kalvin Collins
Japera Parker
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