Reporting Beneficial Ownership Information (BOI) to the Financial Crimes Enforcement Network (FinCEN)
Deadline for filing: March 21, 2025
February 18, 2025 – The beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA) are once again back in effect. However, because the Department of the Treasury (Treasury) recognizes that reporting companies may need additional time to comply with their BOI reporting obligations, FinCEN is generally extending the deadline 30 calendar days from February 19, 2025, for most companies.
Background
On January 7, 2025, the U.S. District Court for the Eastern District of Texas issued an order staying FinCEN’s regulations implementing the BOI reporting requirements, precluding FinCEN from requiring BOI reporting or otherwise enforcing the CTA’s requirements. On February 5, 2025, the U.S. Department of Justice—on behalf of Treasury—filed a notice of appeal of the district court’s order and, in parallel, requested a stay of the order during the appeal.
On February 18, 2025, the court agreed to stay its January 7, 2025, order until the appeal is completed. Given this decision, FinCEN’s regulations implementing the BOI reporting requirements of the CTA are no longer stayed. Thus, subject to any applicable court orders, BOI reporting is now mandatory, but FinCEN is providing additional time for companies to report.
Additional Helpful Resources for Businesses:
- For more information: Beneficial Ownership Information Reporting | FinCEN.gov
- Small business resources: Small Business Resources | FinCEN.gov
- Sign up for updates: https://service.govdelivery.com/accounts/USFINCEN/subscriber/new
- Questions: Contact Us | FinCEN.gov
Corporate Transparency Act Reporting Requirements – Recorded Webinar
Webinar aired in October 2024.
Mark High, Member, Detroit office of Dickinson Wright PLLC and Alexis Lupo, Corporations Division Director; Michigan Department of Licensing & Regulatory Affairs (LARA) Corporations, Securities & Commercial Licensing Bureau will be presenting on the CTA reporting. It is important that Small to Mid-sized businesses learn about reporting this information to FinCEN.