UPDATE: Latest Developments with the Corporate Transparency Act

UPDATE: Latest Developments with the Corporate Transparency Act

In the continuing saga that is the Corporate Transparency Act (“CTA”), please be advised that on February 18, 2025 the U.S. District Court for the Eastern District of Texas in Smith, et al. v. U.S. Department of the Treasury lifted the national stay/pause on the beneficial ownership information (BOI) reporting requirements under the CTA, which are now back in effect.

To support reporting companies during this transition, the Department of the Treasury has extended the deadline by 30 days, setting the new filing deadline to March 21, 2025, for most companies. This applies to initial, updated, and/or corrected BOI reports. It is likely that additional court rulings will continue to impact the enforcement of the CTA, so we will continue to keep our clients informed. Also, on February 18^th, FinCEN published notice that it “will assess its options to further modify deadlines, while prioritizing reporting for those entities that pose the most significant national security risks” and that it “also intends to initiate a process this year to revise the BOI reporting rule to reduce burden for lower-risk entities, including many U.S. small businesses.” Hopefully this new focus by FinCEN, along with pending legislation in Congress, will eventually provide relief to community associations.

In the meantime, to best serve our clients, as well as due to FinCEN’s failure to grant community associations an exemption, our law firm has partnered with a CTA reporting vendor named FincenFetch to establish a secure, ready-made solution as a service to our clients to file their Beneficial Ownership Information Reports with FinCEN. Information on this service can be found here.

As always, associations should continue to monitor ongoing developments regarding the various court cases involving CTA, with particular attention to new reporting deadlines. We will work to provide updated information on our website in the CWMEB Journal, but associations may also monitor other sources of information and media outlets, including updates from the Community Associations Institute.