CTA Reporting Obligation Reinstated

CTA Reporting Obligation Reinstated

As a result of the February 18 decision by the Eastern District of Texas to stay the nationwide preliminary injunction previously granted in Smith v. US Department of the Treasury, reporting obligations under the Corporate Transparency Act (“CTA”) are enforceable.

Yesterday, FinCEN announced March 21, 2025, as the deadline for filing the Beneficial Ownership Information Reports (“BOI Reports”) unless the reporting entity qualifies for a different deadline as a result of certain disaster relief deadlines or based on its formation date.

BOI Reports are filed directly with FinCEN at https://boiefiling.fincen.gov/fileboir.

FinCEN also announced its intention to review the reporting rule to reduce the burden on “lower-risk entities,” but it is unclear how that term may be defined or what modifications to the rule may be made.  Therefore, we recommend that reporting entities plan to comply by the March 21, 2025, deadline.

Should you have questions regarding the CTA or need assistance determining who should be included in a BOI Report, please contact one of the following attorneys in our Business Department: Katie Wahl, Jerry McDonald, Dave Montgomery, or Marcella McHenry at 937.223.1130 or through https://pselaw.com/.