CTA Is In Effect, For Now

Sasha A. Pezenik

February 19, 2025

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As of today, the Corporate Transparency Act (the “CTA”) is back in effect, with the deadline to file Beneficial Ownership Information (“BOI”) extended to March 21, 2025 for those entities that are not exempt from filing.

FinCEN announced that it would provide an update before the March 21, 2025 deadline, of any further modifications of the deadline, recognizing that companies “….may need additional time to comply with their BOI reporting obligations…”. Notably, FinCEN’s statement expressed that FinCEN “… intends to initiate a process this year to revise the BOI reporting rule to reduce the burden for lower-risk entities, including many U.S. small businesses.”

We recommend that companies prepare to file their BOI reports to comply with the CTA before the March 21, 2025 filing deadline for those entities that are not exempt and are required to file before such date under prior deadlines, but confirm with counsel whether there have been any extensions or exemptions which alter their filing requirements prior to actually filing.

We are continuing to monitor all CTA developments. For more information on the Corporate Transparency Act, please click here.

As the law continues to evolve on these matters, please note that this article is current as of date and time of publication and may not reflect subsequent developments. The content and interpretation of the issues addressed herein is subject to change. Cole Schotz P.C. disclaims any and all liability with respect to actions taken or not taken based on any or all of the contents of this publication to the fullest extent permitted by law. This is for general informational purposes and does not constitute legal advice or create an attorney-client relationship. Do not act or refrain from acting upon the information contained in this publication without obtaining legal, financial and tax advice. For further information, please do not hesitate to reach out to your firm contact or to any of the attorneys listed in this publication.