The filing requirements under the Corporate Transparency Act (“CTA”) have once again been restored. In yet another reversal of the on again, off again saga, on February 18, 2025, the U.S. District Court for the Eastern District of Texas in Smith, et al. v. U.S. Department of the Treasury, et al., 6:24-cv-00336 (E.D. Tex.) stayed a previous injunction which had halted the Treasury Department’s Financial Crimes Enforcement Network (“FinCen”) from enforcing its beneficial ownership {“BOI”} filing requirements.
For the vast majority of reporting companies, the new deadline to file an initial, updated, and/or corrected BOI report is now March 21, 2025. Reporting companies formed or registered on or after February 18, 2025, must file within 30 days from the date of creation or registration.
FinCen, in its new alert suggested that it will assess its options to further modify deadlines, while prioritizing reporting for those entities that pose the most significant national security risks. FinCEN indicated that it also intends to initiate a process this year to revise the beneficial ownership reporting rules to reduce the burden for lower-risk entities, including many U.S. small businesses.
