Last Injunction of the Corporate Transparency Act Lifted – BOI Reporting Deadline of March 21, 2025
By now you are probably growing weary of the back and forth on the reporting deadlines for the Corporation Transparency Act’s Beneficial Ownership Information reporting requirements (also known as “BOI”). Well, hold strong because here is one more update after another major court ruling.
On February 18, 2025, the U.S. District Court for the Eastern District of Texas ruled in Samantha Smith and Robert Means vs. U.S. Department of Treasury, et al, that the deadline to report the BOI is back in effect. With this lift of the prior injunction, the Financial Crimes Enforcement Network (FinCEN) reported an extension of 30 days from February 19, 2025 for the initial BOI filing deadline to March 21, 2025. During this 30-day period the FinCEN will assess options to further modify deadlines.
The FinCEN is advising those reporting companies that were previously given a later reporting deadline to file their BOI report by that later deadline. For example, if a company’s reporting deadline was extended to May 2025 because it qualifies for certain disaster relief extensions, it should follow the that deadline. More information is available at the following link Beneficial Ownership Information Reporting | FinCEN.gov.
Finally, the FinCEN website is advising the reporting requirements previously extended for those in areas that were impacted by Hurricane Beryl, Hurricane Debby, Hurricane Francine, Hurricane Helene, and Hurricane Milton, will be further reviewed for possible modification prior to March 21, 2025. Here is a link to Alerts issued for FinCEN, including this latest announcement, additional updates concerning the BOI reporting requirements and extension information for those impacted by the various hurricanes: https://fincen.gov/boi.
If your Association has not already voluntarily submitted the beneficial ownership information reports, and you have any questions concerning whether your Association should do so, please contact your Association’s general counsel prior to March 21, 2025.