February 2025 – BOI REPORTING – MARCH DEADLINE SUSPENDED, PENALTIES & FINES PAUSED

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BOI REPORTING – MARCH DEADLINE SUSPENDED, PENALTIES & FINES PAUSED

 

OVERVIEW

 

We are reaching out with another time-sensitive update of the latest developments regarding the Beneficial Ownership Information (BOI) reporting requirements under the Corporate Transparency Act (CTA).

 

Late yesterday, February 27, 2025, the Financial Crimes Enforcement Network (FinCEN) announced the following:

 

·     Applicable until FinCEN’s next press release (on or before March 21, 2025):

·     No fines or penalties will be issued, and no enforcement actions will be taken related to BOI reporting/filing requirements.

·     On or before March 21, 2025 (which is the current extended BOI reporting due date), FinCEN will issue an interim final rule extending BOI reporting deadlines.

 

According to the press release, FinCEN recognizes the need to provide new guidance and clarity as quickly as possible, and also intends to solicit public feedback on potential revisions to the current BOI reporting requirements to ease the burden on small businesses.

 

CONSIDERATIONS

 

·     The original extended deadline of March 21st has been suspended – we will learn more from FinCEN’s next press release.

·      Legislation is still in process to delay the beneficial ownership information mandatory reporting requirement due date to January 1, 2026 for entities formed prior to January 1, 2024.

·     The bill passed the House and has now been sent to the Senate, so another decision on BOI reporting appears to be pending.

 

NEXT STEPS

 

As the due date of March 21st, 2025 has now been suspended – 

 

·     If you have already filed your BOI report, no further action is necessary. However, we strongly encourage you to stay informed regarding future guidance around BOI reporting.

 

·     If you have not yet filed your BOI report but have a reporting requirement according to the current guidance – we recommend that you wait to file your BOI reporting until further guidance from FinCEN is issued in the coming days.  

·      During this waiting period, we do recommend that you stay informed and still prepare to file your BOI reports should future guidance determine that you still have a reporting requirement.

 

If you have any questions regarding this development and how it may apply to you, we strongly encourage you to consult with your legal counsel for guidance as soon as possible.