Important Legal Update: Corporate Transparency Act- Reporting Requirements Back in Effect with Deadline of March 21, 2025
The Corporate Transparency Act (“CTA”) and its beneficial ownership information (“BOI”) reporting requirements are back in effect. On February 18, 2025, the U.S. District Court for the Eastern District of Texas issued a ruling that reinstated CTA compliance requirements. In response to the ruling, the Financial Crimes Enforcement Network (“FinCEN”) extended the filing deadline for the vast majority of companies to file initial BOI reports to March 21, 2025. Reporting companies should ensure federal compliance by filing an initial report by this deadline.
Even though the reporting requirement is once again mandatory, further updates are no doubt forthcoming. In addition to ongoing CTA litigation, FinCEN plans to revise the Reporting Rule to reduce the burden of reporting on small businesses. We encourage you to sign up to our blog posts and email notifications to stay updated.
If you have concerns about your entity’s compliance or any other questions about filing a BOI report, you should seek the advice of counsel. Additionally, FinCEN has published several helpful resources at https://www.fincen.gov/boi/small-business-resources.
You can also learn more about the CTA requirements by reading our original blog post, found here.
About the Authors
J. Thomas O'Brien, Jr. heads the firm's mergers and acquisitions (M&A) team and serves as outside general counsel to many of the firm's clients. Tom frequently counsels business owners in entity formation and exit strategy planning.
Edward B. Lumpkin works with a broad range of for-profit and non-profit organizations, from start-up ventures to public companies, on a wide variety of matters, with an emphasis on mergers and acquisitions, joint ventures, franchising and licensing arrangements and general corporate, regulatory and securities matters.
Sam Serra Cerchio After working with Spotts Fain as a law clerk for two years, Sam Cerchio has graduated from law school, passed the bar and joined Spotts Fain as an Associate in the firm's Business and Litigation sections.
Spotts Fain publications are provided as an educational service and are not meant to be and should not be construed as legal advice. Readers with particular needs on specific issues should retain the services of competent counsel.