Beneficial Ownership Information Reporting Is Back On

Following a February 18th U.S. District Court ruling, beneficial ownership information reporting (BOIR) requirements under the Corporate Transparency Act (CTA) are back in effect with a new filing deadline of March 21, 2025.

However, FinCEN announced on February 27th that no fines, penalties, or enforcement actions will be taken against any reporting company which fails to file or comply with current BOIR requirements subject to the CTA until an interim final rule becomes effective and corresponding deadlines have passed.

FinCEN is expected to issue an interim final rule no later than March 21, 2025.

Reporting companies that have yet to file their beneficial ownership information (BOI) reports should take the time to compile all requisite information and be prepared to act accordingly.

Beneficial ownership information reports can typically be filed directly by businesses and don’t require third-party involvement; however, businesses that choose to work with a third-party should carefully vet any third-party entities before providing any information necessary for the filing.

Unfortunately, there are bad actors and scammers that will attempt to capitalize on the BOIR requirements including, but not limited to:

• Providing misinformation about current filing requirements and generating a false sense of urgency related to compliance which is contrary to current guidance

• Charging exorbitant fees to “handle” the filing (there is no fee to file a beneficial ownership information report directly with FinCEN)

• Collecting sensitive or personally identifiable information (PII) from BOI filings for unscrupulous purposes

Stay vigilant! Exercise due diligence!