Small Business Owners Alert: Corporate Transparency Act Reporting Requirements Reinstated

Critical Updates to the Beneficial Ownership Information Reporting Requirements

We wanted to inform you of a significant development regarding the Beneficial Ownership Information (“BOI”) reporting requirements under the Corporate Transparency Act (“CTA”).

On December 23, 2024, a federal Court of Appeals decision lifted the preliminary injunction that temporarily suspended the requirement for reporting companies to submit BOI reports to the Financial Crimes Enforcement Network (“FinCen”). As a result, the reporting requirements are back in effect. The U.S. Department of the Treasury has extended the deadlines to assist businesses in complying with the requirements after the recent suspension.

The new deadlines for filing BOI reports are as follows:

1. Companies Created or Registered Before January 1, 2024: Must file their initial BOI reports by January 13, 2025. This extension applies to companies that would have otherwise had a deadline of January 1, 2025.
2. Companies Created or Registered On or After September 4, 2024: Must file their initial BOI reports by January 13, 2024.
3. Companies Created or Registered Between December 3, 2024 and December 23, 2024: These companies will have 21 additional days from their original filing deadline to submit their reports.
4. Disaster Relief Extensions: Companies that qualify for disaster relief may have deadlines that extend beyond January 13, 2025. These businesses should adhere to whichever deadline is later.

Consistent with the original BOI reporting requirements, comanies created or registered on or after January 1, 2025 will have 30 days from their original filing date to file their initial BOI reports.

What Should You Do Next?

Your company should assess its filing deadline and take steps to ensure timely submission of its beneficial ownership information to avoid penalties. If you need assistance with compliance, please contact us for guidance.

We will continue to monitor any additional updates regarding this matter and will keep you informed.

Please note this is a general overview of developments in the law and does not constitute legal advice. Nothing herein creates an attorney-client relationship between the sender and the recipient. If you have any questions, please feel free to contact Ilana T. Pearl at (212) 701-4011 or via email at IPearl@cullenllp.com, or Gabriella Greenhoward at (212) 510-2204 or via email at GGreenhoward@cullenllp.com.