Corporate Transparency Act Has Been Reinstated: Reporting Companies Are Once Again Required to File with FinCEN
The Corporate Transparency Act (CTA) requires most business entities to file a Beneficial Ownership Information (BOI) report with the Financial Crimes Enforcement Network (FinCEN). On February 18th a US District Court in the Eastern District of Texas ruled in the Smith, et al. v. U.S. Department of the Treasury case that the beneficial ownership information reporting requirements under the CTA are once again back in effect.
For the vast majority of reporting companies, the new deadline to file an initial, updated, and/ or corrected BOI report is now March 21, 2025. In a press release, FinCEN indicated it will provide an update before March 21 if there is any further modification of this deadline. Any reporting companies that previously received a reporting deadline later than March 21, 2025, should follow that later deadline. For example, a company may have an April 2025 deadline because it qualifies for certain disaster relief extensions.
FinCEN has also stated that it will assess its options to further modify deadlines, while prioritizing reporting for those entities that pose the most significant national security risks and that it intends to initiate a process this year to revise the BOI reporting rule to reduce burden for lower-risk entities, including many U.S. small businesses.
We have previously written about compliance with the Corporate Transparency Act. The FinCEN website offers a host of reference materials and guidance for BOIR filing, including a small entity compliance guide.
If you have questions relating to the Federal Corporate Transparency Act or the New York State LLC Transparency Act, contact our business attorneys, Michael F. McConville at mmcconville@mccmlaw.com or 585-512-3520; Letty Laskowski at llaskowski@mccmlaw.com or 585-512-3538; Amy L. Varel at avarel@mccmlaw.com or 585-512-3506.
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About MCCM
McConville Considine Cooman & Morin, P.C. is a full-service law firm based in Rochester, New York, providing high-quality legal services to businesses and individuals since 1979. With over a dozen attorneys and a full paralegal support staff, the firm is well-positioned to right-size services tailored to each client. We are large enough to provide expertise in a broad range of practice areas, yet small enough to devote prompt, personal attention to our clients.
We represent a diverse range of clients located throughout New York State and New England. They include individuals, numerous manufacturing and service industry businesses, local governments, and health care professionals, provider groups, facilities and associations. We also serve as local counsel to out-of-state clients and their attorneys who have litigation pending in Western New York courts. For more information, please contact us at 585.546.2500.