The ongoing saga of the Corporate Transparency Act (CTA) continues! On the evening of February 27, 2025, the Financial Crimes Enforcement Network (FinCEN) announced three key developments.
- Deadline Extension Expected
FinCEN intends to issue an interim final rule no later than March 21, 2025, which will extend the BOI reporting deadlines.
- Enforcement Pause – No Penalties Until New Rule Takes Effect
In a significant move, FinCEN confirmed that it will not issue any fines or penalties for failure to file or update BOI reports by the current deadlines, including the March 21, 2025, deadline for most entities. Enforcement actions will not be taken until the interim final rule is in effect and new deadlines are established.
- Public Comment Solicitation on BOI Reporting Revisions
FinCEN also announced its intention to solicit public comments on potential revisions to the existing BOI reporting requirements. These comments will be taken into account when drafting a notice of proposed rulemaking, which is expected to be issued later this year. The goal of the revised requirements is to balance minimizing the burden on small businesses while ensuring that the information gathered remains useful for national security, intelligence, and law enforcement activities.
What Does This Mean for Your Business?
- You are not required to file initial or amended BOI reports by the current filing deadline (March 21, 2025, for most entities). Until new interim rules are established, no penalties or fines related to the CTA will apply for failing to file.
- Pay attention to the forthcoming interim final rule expected from FinCEN by March 21, 2025, which will provide more clarity and updated deadlines.
- Keep an eye out for opportunities to comment on the proposed revisions to BOI reporting, which could affect your business’s reporting obligations moving forward.
As always, we will continue to monitor the developments related to the CTA and will provide updates as new information becomes available.
