Important Update – Corporate Transparency Act Filing Obligations Reinstated and Mandatory

Here are five key takeaways from the client alert issued by the law firm Polsinelli (Bill Quick, Philip Feigen, Bert Stemmler, and Mark Olthoff):

CTA Filings Are Mandatory Again – Due to the lifting of nationwide injunctions, the Corporate Transparency Act (CTA) beneficial ownership information (BOI) reporting requirements are back in effect, and most reporting companies must file by March 21, 2025.
Extended Deadline and Possible Modifications – FinCEN (Financial Crimes Enforcement Network, US Treasury) has granted a 30-day extension from February 19, 2025, and may further modify deadlines, prioritizing entities posing national security risks.
Court Rulings and Injunctions – The Smith v. Treasury ruling lifted the last remaining injunction, reinstating CTA enforcement. However, other lawsuits, such as National Small Business United v. Yellen, have exempted specific plaintiffs from filing.
Legislative Developments – The U.S. House of Representatives of Representatives passed a bill (408–0) to extend the BOIR deadline for Pre-‘24 Companies to January 1, 2026, but the Senate has yet to approve it. If passed, this would delay filings only for pre-2024 entities.
Uncertain Future Legal and Administrative Actions – Courts remain divided on the CTA’s constitutionality, and the new administration has continued to support CTA enforcement through court filings, though future actions remain uncertain.

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