Corporate Transparency Act Update:

And the CTA Drama Continues…..

By: Amanda Messa

With the February 18, 2025, decision by the U.S. District Court for the Eastern District of Texas in Smith, et al v. U.S. Department of Treasury, et al, 6:24-cv-00336 (E.D. Tex.), beneficial ownership reporting requirements are back in effect, with a new deadline of March 21, 2025 for most companies.  Yes, unfortunately friends, it’s time to dust off your copy of the CTA exemptions to see if a filing is required.  According to a notice posted on FinCEN’s website, FinCEN will assess its options for further modifying deadlines “while prioritizing reporting for those entities that post the most significant national security risks.”  FinCEN has also indicated it intends to initiate a process to revise the BOI reporting rule to reduce the burden for lower-risk entities, including many U.S. small businesses. 

I’m not exactly sure what any of that really means for us but in order to avoid the constant headache of trying to track various pieces of litigation on this topic and the everchanging deadlines, it may be time to just bite the bullet and file those reports if your company does not fall within one of the Act’s exemptions.