Shortly after publication of our December 23, 2024 Client Alert regarding the Fifth Circuit’s reinstatement of the CTA, FinCEN issued guidance administratively extending the deadlines for certain BOI Report filings. Most notably, the January 1, 2025 deadline for reporting companies in existence prior to 2024 has been extended to January 13, 2025. Below is an excerpt of FinCEN’s newly issued guidance that we believe captures the changes that will be most immediately relevant to our clients. The full text of FinCEN’s revised guidance is available here (click “Alert: Updates to Beneficial Ownership Information Reporting Deadlines”).
- Reporting companies that were created or registered prior to January 1, 2024 have until January 13, 2025 to file their initial beneficial ownership information reports with FinCEN. (These companies would otherwise have been required to report by January 1, 2025.)
- Reporting companies created or registered in the United States on or after September 4, 2024 that had a filing deadline between December 3, 2024 and December 23, 2024 have until January 13, 2025 to file their initial beneficial ownership information reports with FinCEN.
- Reporting companies created or registered in the United States on or after December 3, 2024 and on or before December 23, 2024 have an additional 21 days from their original filing deadline to file their initial beneficial ownership information reports with FinCEN.
Our CTA Task Force will continue to monitor for relevant developments, with periodic updates accessible at our CTA resource page.
