On March 2, 2025, the Financial Crimes Enforcement Network (FinCEN) announced that it would no longer enforce the Corporate Transparency Act’s (CTA) deadline to disclose beneficial ownership information (BOI). Therefore, there is nothing further that needs to be done with their requirement of providing information on the beneficial owners of an LLC or other business entities.
This decision comes after a preliminary injunction was issued on reporting requirements in the case Texas Top Cop Shop, Inc., et all v. Garland, et al. that was brought in the U.S. District Court for the Eastern District of Texas. On December 23, 2024, the Fifth Circuit Court of Appeals overturned the injunction and stayed the CTA. In January, a nationwide injunction was issued against the CTA, which led to the courts going back and forth regarding whether the CTA reporting requirements would be enforced. Prior to FinCEN’s decision to suspend the enforcement of the reporting requirements, companies had a deadline of March 21, 2025 to submit the required information.
With FinCEN’s newest take on BOI reporting, companies will not be penalized or fined under the existing regulatory deadlines. Furthermore, it will not penalize or fine any companies after the new rule changes take effect. The FinCEN intends to announce a rule no later than March 21, 2025 to extend the filing deadline, as well as any changes to the scope of the existing rules. The U.S. Department of Treasury also plans to propose a rule that will limit the reporting requirements to foreign companies.
The decision by FinCEN means that if you are a business that fell under the reporting
requirements of the CTA, you are no longer required to submit the previously required information (i.e. full legal names, birth dates, current addresses, and copies of drivers’ licenses) by the previously imposed March 21, 2025 deadline. While the CTA filing obligations still exist, there is no deadline for enforcement. BOI reports can still be voluntarily filed by companies if they choose to do so.
Durnell Maier Law will continue to track developments on the CTA reporting requirements, including any revisions of the scope of the existing rules. If any of our clients are impacted by any future decisions, we will keep you informed.
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