Corporate Transparency Act Compliance Update: BOI Reporting Pushed Out, Enforcement Paused

The Corporate Transparency Act (CTA) continues to evolve, bringing new developments that impact business compliance obligations. In the latest twist, the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has extended the deadline for Beneficial Ownership Information (BOI) reporting and temporarily paused enforcement due to ongoing litigation.

Where Things Stand

• Extended Reporting Deadline: Businesses formed in 2024 now have 90 days (instead of 30) to submit their BOI reports.
• Enforcement Pause: FinCEN has temporarily halted enforcement of BOI reporting requirements while legal challenges play out.
• Ongoing Compliance Obligations: Despite this pause, the CTA remains in effect, and businesses should still prepare for compliance.

Understanding the CTA and BOI Reporting Requirements

The Corporate Transparency Act, which went into effect in 2024, requires most entities (referred to as Reporting Companies) to disclose certain information about their Beneficial Owners and Company Applicants to FinCEN.

Who Is Impacted?

The CTA applies to nearly all business entities formed or registered to do business in the United States, with limited exceptions for:

• Publicly traded companies
• Banks and other regulated financial institutions
• Tax-exempt entities
• Large companies with more than 20 full-time U.S. employees and $5 million in gross receipts

Entities meeting the definition of a Reporting Company must submit BOI reports detailing their Beneficial Owners—individuals who either own 25% or more of the company or exercise substantial control over its operations.

What Businesses Should Do Next

While FinCEN’s recent actions provide some breathing room, companies should not assume the compliance burden has been lifted. The CTA remains in effect, and businesses should stay prepared for full enforcement once the legal challenges are resolved.

Glaser Weil’s attorneys are closely monitoring the evolving regulatory landscape and are available to help businesses navigate CTA compliance. If you have questions about how these changes affect your obligations, contact us today for guidance.

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Access additional background from Glaser Weil (January 2024): Navigating the Corporate Transparency Act: What You Need to Know Now