On February 18, 2025, the United States District Court for the Eastern District of Texas stayed its order dated January 7, 2025 resulting in the reinstitution of the enforcement of the Corporate Transparency Act (CTA) and its deadlines. As explained in more detail here, the CTA requires new and existing companies to disclose to the Financial Crimes Enforcement Network (FinCEN) of the Treasury Department certain beneficial ownership information (BOI) about the individuals who ultimately own or control those reporting companies.
As a result of the timing of the United States District Court decision, FinCEN has extended some of the reporting deadlines, including that (i) reporting companies that would have been required to file reports with FinCEN as of December 31, 2024 will have a 30-day extension of time to file, with a new due date of March 21, 2025 and (ii) reporting companies that were previously given a reporting deadline later than the March 21, 2025 deadline must file their initial BOI report by that later deadline (and not the March 21, 2025 deadline). FinCEN noted that it will be using this 30-day period to assess its options to further modify deadlines.
FinCEN has designed an electronic filing platform specifically for submitting beneficial ownership reports as mandated by the CTA. FinCEN’s website includes a link to the BOI E-Filing System and additional information on reporting exemptions and beneficial ownership.
If you need assistance with reporting beneficial ownership information to FinCEN or guidance regarding compliance with the CTA, please email CTA@utbf.com.
