CSG Law Alert: CTA Reporting Obligations Reinstated – Time to File!
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 its January 7, 2025 order putting mandatory beneficial ownership information (BOI) reporting on hold, and reinstated mandatory BOI reporting obligations under the Corporate Transparency Act (CTA), which, for the vast majority of reporting companies, must be filed by March 21, 2025.
According to FinCEN (FinCEN Notice, FIN-2025-CTA1, 2/18/2025), the Department of Treasury recognizes that reporting companies may need additional time to comply with BOI reporting obligations and FinCEN is, therefore, generally extending the deadline from February 19, 2025 to March 21, 2025 for most companies. During this 30-day period, the government plans to consider additional deadline modifications prioritizing reporting for entities posing the most significant national security risks. FinCEN also intends to initiate a process this year to revise the BOI reporting rule to reduce burden for lower-risk entities, including many U.S. small businesses, which may greatly alleviate the filing burden for many entities. CSG Law will continue to monitor FinCEN notifications, as well as any subsequent legal and administration developments and will keep you posted. Stay tuned for updates!
With this latest ruling, we strongly encourage clients to comply with all applicable BOI reporting obligations prior to the March 21, 2025 deadline.