The state of the law on the Corporate Transparency Act (CTA) has changed once again. Specifically, the prior nationwide injunction issued in Smith v. U.S. Department of Treasury was stayed. This means that the Financial Crimes Enforcement Network (FinCEN) can now enforce the CTA, and reporting companies are required to file beneficial ownership information (BOI) reports under the CTA.

In a recent alert, FinCEN has extended the deadlines for filing BOI reports. Specifically, with few exceptions the new deadline for filing an initial, updated, and/or corrected BOI report is now March 21, 2025.

Reporting companies that have taken a “wait and see” approach must now ensure that they comply with the CTA’s reporting requirements. Reporting companies should confirm that they qualify as “reporting companies” under the CTA, identify beneficial owners, collect the requisite identifying information on the beneficial owners, and ensure that accurate BOI reports are filed, all before the new deadline of March 21, 2025.

Reporting companies would be well advised to consult with their counsel to ensure full compliance with the CTA.