Once again, entities are required to file beneficial ownership information reports (each, a “BOI report”) with the Treasury Department’s Financial Crimes Enforcement Network. On February 18, 2025, the Eastern District of Texas, in Smith, et al. v. U.S. Department of the Treasury, E.D. Tex., 2025, stayed the nationwide injunction against the Corporate Transparency Act (the “CTA”), and thus, reinstated the Beneficial Ownership Information Reporting Rule’s (the “BOI Reporting Rule”) requirement to file BOI reports.

FinCEN extended the filing deadline to March 21, 2025 for most reporting companies, including those reporting companies formed prior to January 1, 2024, but FinCEN has also noted that it will also be considering further modifications to this deadline. In addition, FinCEN stated that it is considering a revision to future reporting requirements to differentiate between lower-risk and higher-risk entities.

Despite FinCEN’s consideration of further modifications and revisions to both the filing deadline and reporting requirements, we recommend that reporting companies prepare BOI reports before the March 21, 2025 deadline. As a reminder from our November 26, 2024 Client Alert, domestic and foreign corporations, limited liability companies and other similar entities that were formed or registered to do business in the United States and are not exempt pursuant to one or more exemptions provided for under the BOI Reporting Rule are required to file BOI reports.