In the past few months, developments related to the Corporate Transparency Act (“CTA”) have proceeded at a near-constant pace. This law has been subject to numerous back-and-forth court rulings. Further, the Financial Crimes Enforcement Network (“FinCEN”) has responded to a number of those rulings by issuing new beneficial ownership information (“BOI”) reporting deadlines.
Recently, FinCEN posted an alert on its official government website extending the deadline to submit BOI reports for most reporting entities to March 21, 2025. On February 27, 2025, FinCEN went even further when it announced, via a press release, that it “will not issue any fines or penalties or take any other enforcement actions against any companies based on any failure to file or update beneficial ownership information (BOI) reports.”
In short, FinCEN seems to be taking the position that the CTA’s reporting requirements are again voluntary, at least for now.
The FinCEN press release further stated it intends to publish a revised rule related to the CTA that it says will lessen the reporting obligations for many entities and will provide for new reporting deadlines. This revised rule with updated deadlines is to be published no later than March 21, 2025.
Meanwhile, there have also been several bills introduced to the House of Representatives that would either further delay the implementation of the CTA or repeal it completely. A bill to delay the reporting obligations of the CTA until January 1, 2026, passed the House of Representatives with bipartisan support and has been referred to the Senate for review.
If you have questions about your obligations under the current CTA or would like further guidance, please contact your FGKS Law attorney today.
