Federal Court Lifts Injunction of Mammoth Reporting Obligations, FinCEN Imposes New Filing Deadline of March 21
On February 17, 2025, a Texas Federal Court lifted its preliminary injunction of the mammoth beneficial ownership information (“BOI”) reporting requirements under the Corporate Transparency Act (“CTA”). The CTA affects most small businesses in Colorado. You can read the Federal Court’s order here:
Following the court’s decision, the U.S. Treasury Department, through its Financial Crimes Enforcement Network (FinCEN), published a notice on its website alerting reporting companies that the new deadline to file BOI reports for most companies is now March 21, 2025. To determine whether the new filing deadline applies to your small business, check out FinCEN’s notice:
During the period between now and March 21, FinCEN has announced plans to assess options to further modify filing deadlines and also to look for ways to prioritize reporting for entities that pose “the most significant national security risks.” In the meantime, legal challenges to the CTA’s constitutionality continue and Congress is actively considering legislative modifications to the CTA’s filing deadlines.
At least for now, all future filing deadlines are likely once again in effect for newly formed reporting companies and also for changes to previously filed BOI reports.
The CTA’s extinction, de-extinction lifecycle over the past several months has caused great confusion for most small businesses, who (together with their corporate leaders) face the threat of criminal penalties ($10,000), jail time (2 years), and civil fines ($500/day) for noncompliance with the CTA’s reporting requirements.
For background, helpful reference materials, and future alerts concerning the law and its enforcement, refer to FinCEN’s official website at https://fincen.gov/boi.
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