On February 18, 2025, the U.S. District Court for the Eastern District of Texas granted the federal government’s motion for a stay pending appeal and lifted the nationwide preliminary injunction in Smith, et al. v. U.S. Department of the Treasury, et al., 6:24-cv-00336 (E.D. Tex.). The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN), in response to the court’s order, subsequently released a public statement confirming that the Beneficial Ownership Information (BOI) reporting requirements under the Corporate Transparency Act (CTA) are back in effect; however, many reporting companies have been granted filing extensions for their initial, updated, and corrected BOI reports. 

The New Filing Deadlines

• For the vast majority of reporting companies, the new deadline to file initial, updated, or corrected BOI reports is now March 21, 2025.
• Reporting companies that have previously been granted a disaster relief or other deadline extension which is later than March 21, 2025 still have until that later deadline to file their initial BOI report. 
• Once an initial, updated, or corrected BOI report has been filed between now and the March 21, 2025 deadline, reporting companies will thereafter have 30 calendar days to submit updated and/or corrected reports. 
• Reporting companies formed or registered after February 19, 2025 will have 30 calendar days from the date of formation or registration to file an initial BOI report.

FinCEN has indicated that between now and March 21, 2025 it will, “assess its options to further modify deadlines, while prioritizing reporting for those entities that pose the most significant national security risks. FinCEN also 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.”

Please contact your attorney at Wilson Sonsini for more information.