2/27/25 Update: 

Last week, the Financial Crimes Enforcement Network (FinCEN) made significant announcements regarding the enforcement of Beneficial Ownership Information (BOI) reporting requirements. On Monday, February 17, 2025, a U.S. District Court judge lifted the final nationwide injunction that had previously halted BOI report filings.

Reporting companies now have until March 21, 2025, to file their initial, updated, or corrected BOI reports. However, companies with later deadlines—for example, those qualifying for disaster relief extensions—may file by their original, extended deadline.

FinCEN also announced it will spend the next 30 days evaluating potential deadline adjustments while prioritizing reports from entities that pose the greatest national security risks. Additionally, FinCEN plans to revise the BOI reporting rule later this year to ease the burden on lower-risk entities, including many U.S. small businesses.

FinCEN stated it would provide an update on any further deadline changes to allow reporting companies additional time to comply with BOI requirements, if necessary.

 

1/24/25 Update: In recent weeks, the nationwide Beneficial Ownership Information (BOI Filing) reporting requirements have shifted for business owners. Since the December 3, 2024 preliminary injunction that halted the requirements, the decision has been reversed twice. On December 23, the Department of Justice’s emergency notion that lifted the injunction was granted by the Fifth Circuit Court of Appeals. Just three days later, the decision was reversed, and FinCEN updated its reporting requirements. On December 31, the Department of Justice filed its “Application for a Stay of the Injunction” with the United States Supreme Court. As of today, the injunction stands and businesses are not required to file. However, as we’ve seen in recent weeks, the decision can quickly change, so it’s best to stay ready.

This article is an update from a previously published article about BOI Reporting.

12/17/24 Update: As we approach the original January 1, 2025, deadline for BOI reporting, a major development has shifted the compliance landscape for businesses. A recent federal court decision has temporarily paused enforcement of the BOI filing requirements outlined in the Corporate Transparency Act (CTA). Here’s what this means for your business and why it’s still essential to stay prepared. 

What Is the Recent Update? 

On December 3, 2024, a federal court in Texas issued a nationwide preliminary injunction against the enforcement of BOI reporting requirements. The court’s decision, part of the case Texas Top Cop Shop v. Garland, ruled that Congress likely exceeded its constitutional authority in enacting the CTA. This decision means that businesses are temporarily no longer required to file BOI reports with the Financial Crimes Enforcement Network (FinCEN) by the previously set January 1 deadline. 

While this ruling is significant, it’s important to note that it is subject to appeal. If overturned, the reporting requirements could be reinstated, and businesses may need to act quickly to comply. 

What Does This Mean for Your Business? 

For now, businesses are not required to file BOI reports, but this could change depending on further court rulings or legislative action. The suspension provides a temporary reprieve, but the potential for reinstatement means that businesses should not disregard preparation entirely. Failing to comply with BOI requirements if they are reinstated could result in significant penalties. 

Why You Should Stay Prepared 

While the immediate filing obligation is on hold, staying prepared is a prudent course of action. Here are steps to ensure readiness: 

  • Organize Ownership Records: Ensure your business has accurate and up-to-date information on all beneficial owners, including individuals with substantial control or a significant ownership stake. 
  • Understand Reporting Obligations: Familiarize yourself with the types of information required under the CTA, such as names, addresses, dates of birth, and identification numbers for beneficial owners. 
  • Monitor Developments: Stay informed about any changes to the injunction or new rulings that may impact the filing requirements. 

Being proactive now could save your business from last-minute compliance challenges if the requirements are reinstated. 

How Abacus! Can Help 

At Abacus!, we understand the complexities of BOI reporting and are here to help you navigate this evolving situation. Our team is closely monitoring the legal and regulatory updates and is prepared to assist you in staying compliant, whether or not the filing requirements resume. 

We offer: 

  • Consultations on BOI Compliance: Assess your current readiness and identify any gaps in ownership recordkeeping. 
  • Educational Resources: Provide clarity on the CTA and its implications for your business. 
  • Ongoing Updates: Keep you informed about changes to the legal landscape affecting BOI reporting. 

Final Thoughts 

While the recent court ruling has paused BOI filing requirements, this is a developing situation that businesses cannot afford to ignore. Taking steps now to prepare for potential compliance will put your business in a stronger position should the requirements be reinstated. 

If you have any questions or want to ensure your business is ready for any eventuality, contact our BOI partners at info@fincenboi.biz or (417) 444-6300. Our team is here to provide expert guidance and support.