The BOI Reporting saga continues…
In the latest development, the Financial Crimes Enforcement Network (FinCEN) has reinstated the Beneficial Ownership Information (BOI) reporting requirements under the Corporate Transparency Act (CTA). This follows a recent federal court decision that lifted the previous nationwide injunction, thereby reactivating the mandate for entities to disclose their beneficial ownership details.
**DISCLAIMER: FinCEN has said they may issue additional reporting deadline extensions or other guidance relating to BOI reporting.**
FinCEN has extended the previous BOI reporting deadline, providing most reporting companies until March 21, 2025, to submit their initial, updated, or corrected reports. This extension acknowledges the need for businesses to adapt to the reinstated requirements. FinCEN has also indicated that it will assess options to further modify deadlines, prioritizing entities that pose significant national security risks.
Entities previously granted reporting deadlines beyond March 21, 2025, must adhere to their original timelines. For instance, companies qualifying for disaster relief extensions with deadlines in April 2025 should comply with the April date
In an effort to reduce regulatory burdens on lower-risk entities, including many U.S. small businesses, FinCEN plans to initiate a process this year to revise the BOI reporting rules. This initiative aims to streamline compliance while maintaining the integrity of financial oversight.
How Does This Update Impact You?
With the new deadline for companies to file an initial, updated, and/or corrected BOI report being March 21, 2025, this means:
- Non-exempt reporting companies formed on or before February 19, 2025, will have until March 21, 2025 to file their BOI reports.
- Non-exempt reporting companies formed after February 19, 2025, will have 30 days from their formation/registration to file their BOI reports (unless they otherwise qualify for a later deadline, e.g., disaster relief extension).
However, be mindful that FinCEN may issue additional reporting deadline extensions or other guidance relating to BOI reporting. Thus, companies should be prepared to respond to those updates, if/when they come about.
Reporting companies can file their beneficial ownership information directly to FinCEN using FinCEN’s E-Filing system, available at https://boiefiling.fincen.gov/.
Mills Wealth will continue to monitor relevant developments and keep you informed of any news or updates that transpire on this topic. If you have any questions related to BOI reporting or its application to your business, please don’t hesitate to reach out.
For more information regarding this topic, please visit the FinCEN website using the following link: https://www.fincen.gov/boi.