On February 18, 2025, the U.S. District Court for the Eastern District of Texas in Smith, et al. v. U.S. Department of the Treasury, et al., 6:24-cv-00336 (E.D. Tex.) held that beneficial ownership information (“BOI”) reporting requirements under the Corporate Transparency Act (the “CTA”) were back in effect. Accordingly, the Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) extended the reporting deadline until March 21, 2025.
However, FinCEN has once again adjusted its stance on reporting requirements. On February 27, 2025, FinCEN issued a press release announcing that it will not be issuing any fines or penalties against any companies who fail to comply with the current reporting deadlines. FinCEN anticipates issuing a final rule extending BOI reporting deadlines and providing guidance and clarity no later than March 21, 2025.
Due to the fluid situation with reporting requirements, those interested should continue to monitor developments and reach out to the Transactional Department at Cuddy & Feder LLP with any questions.
