As of today, the Corporate Transparency Act (the “CTA”) is back in effect, with the deadline to file Beneficial Ownership Information (“BOI”) extended to March 21, 2025 for those entities that are not exempt from filing.
FinCEN announced that it would provide an update before the March 21, 2025 deadline, of any further modifications of the deadline, recognizing that companies “….may need additional time to comply with their BOI reporting obligations…”. Notably, FinCEN’s statement expressed that FinCEN “… intends to initiate a process this year to revise the BOI reporting rule to reduce the burden for lower-risk entities, including many U.S. small businesses.”
We recommend that companies prepare to file their BOI reports to comply with the CTA before the March 21, 2025 filing deadline for those entities that are not exempt and are required to file before such date under prior deadlines, but confirm with counsel whether there have been any extensions or exemptions which alter their filing requirements prior to actually filing.