Corporate Transparency Act Reinstated With New March 21, 2025 Deadline

Many entities now have until March 21, 2025, to file their initial Beneficial Ownership Information Reports. On February 18, 2025, the Financial Crimes Enforcement Network (FinCEN) published a notice stating that it would resume enforcement of the Corporate Transparency Act (CTA) and established a new deadline of March 21, 2025, for Reporting Companies to file their initial Beneficial Ownership Information reports. This follows a decision by a federal judge to end the nationwide injunction preventing enforcement of the CTA. Reporting Companies formed after February 18, 2025, will have 30 days to file their initial Beneficial Ownership Information Reports. This deadline also applies to Reporting Companies who previously filed reports and who have since experienced a beneficial ownership information change prior to February 18, 2025, and are now required to file an updated report. For more on determining whether your entity is a Reporting Company, please see our previous alert here and the relevant FinCEN resources found here.

Please note that further developments may occur. FinCEN indicated that in the next 30 days it will consider further modifying the reporting deadline and begin a process to revise the reporting rule to reduce the burden of filing. Additionally, while the latest injunction has ended, there are multiple ongoing cases challenging the CTA. The U.S. House of Representatives has also passed H.R. 736, which would allow FinCEN to extend the compliance deadline for entities formed prior to January 1, 2024. Reinhart will continue to monitor developments. For more information and questions, contact a member of the Corporate Law Practice or your Reinhart attorney.