Pearl Cohen U.S. Corporate and Securities Group
On February 17, 2025, the U.S. District Court for the Eastern District of Texas granted FinCEN a stay on its previously issued preliminary injunction, reinstating the enforcement of the Corporate Transparency Act (CTA) nationwide. As a result, Beneficial Ownership Information (BOI) reporting requirements are once again mandatory for all non-exempt reporting companies.
FinCEN has issued new filing deadlines to provide reporting companies additional time to comply:
• For most reporting companies, the new deadline to file an initial, updated, and/or corrected BOI report is now March 21, 2025.
• Reporting companies formed or registered on or after February 18, 2025, must file within 30 days from the date of creation or registration.
• 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. For example, if a company’s reporting deadline is in April 2025 because it qualifies for certain disaster relief extensions, it should follow the April deadline, not the March deadline.
FinCEN has stated it will assess its options for further modifying deadlines. In the meantime, BOI reporting requirements are back in effect.
There are ongoing efforts in Congress to change the CTA’s reporting requirements; however, no legislation has been passed in this respect.
For more information and to file BOI reports, visit FinCEN’s BOI E-Filing System at https://boiefiling.fincen.gov.
For additional information about the CTA’s reporting requirements and how it may apply to you and your company, please do not hesitate to contact us:
Oded Kadosh at okadosh@pearlcohen.com
Guy Milhalter at gmilhalter@pearlcohen.com
Austin Ochoa at aochoa@pearlcohen.com
