Shortly after publication of our December 23, 2024 Client Alert regarding the Fifth Circuit’s reinstatement of the CTA, FinCEN issued guidance administratively extending the deadlines for certain BOI Report filings. Most notably, the January 1, 2025 deadline for reporting companies in existence prior to 2024 has been extended to January 13, 2025. Below is an excerpt of FinCEN’s newly issued guidance that we believe captures the changes that will be most immediately relevant to our clients. The full text of FinCEN’s revised guidance is available here (click “Alert: Updates to Beneficial Ownership Information Reporting Deadlines”).
- Reporting companies that were created or registered prior to January 1, 2024 have until January 13, 2025 to file their initial beneficial ownership information reports with FinCEN. (These companies would otherwise have been required to report by January 1, 2025.)
- Reporting companies created or registered in the United States on or after September 4, 2024 that had a filing deadline between December 3, 2024 and December 23, 2024 have until January 13, 2025 to file their initial beneficial ownership information reports with FinCEN.
- Reporting companies created or registered in the United States on or after December 3, 2024 and on or before December 23, 2024 have an additional 21 days from their original filing deadline to file their initial beneficial ownership information reports with FinCEN.
Our CTA Task Force will continue to monitor for relevant developments, with periodic updates accessible at our CTA resource page. If you have any questions or need advice about CTA or its application to your business, please contact one of the members of the CTA Task Force or your primary Bass, Berry & Sims attorney.
This alert is not intended to, and does not, provide legal, compliance or other advice to any person, and receipt of this document does not constitute the establishment of an attorney-client relationship. The information and analysis set forth in this document is subject to change based on new regulations and regulatory guidance, and other circumstances. Applicability of the CTA can be subject to a detailed factual analysis. Entities and individuals should consult with their attorney for specific CTA advice.