BOI Reporting Enforcement Updates
We’ve been hard at work keeping up with the myriad of developments relating to Beneficial Ownership Information (BOI) reporting. In the future, all BOI updates will be added to this convenient location and appear in the order of the most recent notification.
For now, enforcement of BOI filing is delayed. The Financial Crimes Enforcement Network (FinCEN), the governing body enforcing the reporting requirements under the Corporate Transparency Act (CTA), will issue an interim final rule no later than March 21, 2025. As a result of repeated delays, the Treasury Department has determined that no fines or penalties will be imposed in connection with BOI reporting deadlines.
What Are Your Options During the Delay Period?
The lack of clarity about the implementation and enforcement of BOI reporting leaves small businesses with three potential approaches:
Timeline of BOI Reporting Events:
- UPCOMING on 3/25/2025: Fifth Circuit arguments scheduled to address the government’s appeal on the injunction.
- 2/27/2025: FinCEN announces no fines or penalties in connection with BOI reporting deadlines.
- 2/18/2025: FinCEN extends BOI reporting deadline by 30 days; Announces Intention to Revise Reporting Rule.
- 12/31/2024: The federal government requests the U.S. Supreme Court to unblock BOI enforcement.
- 12/26/2024: Fifth Circuit vacates the stay, reinstating the nationwide injunction.
- 12/23/2024: Fifth Circuit temporarily lifts the injunction, enabling BOI enforcement. FinCEN extends the due date for most filers to January 13, 2025.
- 12/18/2024: Congressional Budget Reconciliation Bill removes extension for BOI reporting deadlines.
- 1/2/2024: Nationwide injunction issued by a Texas federal judge, halting BOI enforcement.
- 1/12024: CTA Beneficial Ownership Reporting requirements take effect for new entities, with a delay for existing entities until January 1, 2025.
- 9/27/2023: Beneficial Ownership Information Reporting Deadline Extension
- 1/1/2021: Corporate Transparency Act enacted.
Support From Our Team
Grimbleby Coleman collaborates with law firms and service providers to assist businesses in meeting BOI reporting requirements. For more information or guidance, contact your Grimbleby Coleman advisor or connect with a team member for assistance.
