Welcome Back, CTA Reporting Requirements!

In the latest in a series of back-and-forth developments, the Beneficial Ownership Information (BOI) reporting requirements under the Corporate Transparency Act (CTA) are back in effect. This newest change follows a February 17, 2025 federal district court decision that granted the Treasury Department’s motion to stay a prior injunction in Smith v. United States Department of the Treasury. As a result, the Financial Crimes Enforcement Network (FinCEN) can resume enforcement of BOI reporting requirements. 

New Compliance Deadlines

With the reinstatement of the CTA’s reporting obligations, FinCEN has extended the deadline to March 21, 2025 for most reporting companies to file their initial, updated, or corrected BOI reports. However, for entities that were already subject to later filing deadlines due to disaster relief extensions or other reasons, those later deadlines remain applicable. 

FinCEN has also indicated that it is assessing potential modifications to reporting requirements, particularly for lower-risk entities, which may lead to further adjustments in the compliance timeline. 

Legal and Legislative Uncertainty

Legislative efforts to extend BOI reporting deadlines continue. The U.S. House of Representatives has passed the Protect Small Business from Excessive Paperwork Act of 2025, which, if enacted, would push the compliance deadline for companies formed before January 1, 2024 to January 1, 2026. A companion bill is currently pending in the U.S. Senate. 

Next Steps for Affected Companies

Given the shifting regulatory landscape, companies should determine whether they are subject to BOI reporting requirements and prepare to file by the applicable deadline. You can find more information about the CTA and reporting requirements on the Ellin & Tucker website, in an insight entitled What’s the Corporate Transparency All About? Additionally, companies and organizations should also monitor ongoing legal and legislative developments that may further affect compliance obligations. 

For now, the CTA’s BOI reporting requirements remain in effect, and entities must ensure timely compliance to avoid potential penalties. 

Most importantly, unlike other report filing processes, your CPA cannot help you with this one. Advising clients regarding the legal or regulatory aspects of their compliance with CTA is the responsibility of qualified legal counsel, not a CPA. Ellin & Tucker strongly encourages business owners to consult with qualified legal counsel when filing this report. 

You can visit https://www.fincen.gov/boi-faqs for more information, or as always, you can reach out to your team at Ellin & Tucker to have a conversation about how your reporting entity might be affected.