In light of a recent order by the Fifth Circuit released on December 23, 2024, reporting companies are once again required to file beneficial ownership information (“BOI”) required by the Corporate Transparency Act (“CTA”) with the Financial Crimes Enforcement Network (“FinCEN”). In response to this latest development, FinCEN has extended the deadline for certain reporting companies as follows:
- Reporting Companies Created or Registered Prior to January 1, 2024: These companies now have until January 13, 2025 to file their initial BOI reports with FinCEN.
Note that previously these companies would have been required to report by January 1, 2025.
- Reporting Companies Created or Registered Between September 4, 2024 and December 23, 2024: These companies now have until January 13, 2025 to file their BOI reports.
Note that previously, these companies would have been required to file their initial BOI reports between December 3, 2024, and December 23, 2024.
- Reporting Companies Created or Registered Between December 3, 2024 and December 23, 2024: These companies are granted an additional 21 days from their original filing deadline to submit their BOI reports.
- Reporting Companies Created or Registered After January 1, 2025: These companies will have 30 days from the date of receiving actual or public notice that their creation or registration is effective to file their initial BOI reports with FinCEN.
The Plaintiffs in the Fifth Circuit case, Texas Top Cop Shop v. Garland, have petitioned the Fifth Circuit to review the December 23, 2024 order, en banc, and issue a ruling on its review by January 6, 2025. However, we recommend all reporting companies prepare to comply with the extended compliance deadlines noted above.
Please note that the ongoing legal challenges to the CTA may result in further developments and our team will continue to monitor and send updates as the situation further develops.
