On February 18, 2025, the U.S. District Court for the Eastern District of Texas issued an order staying its previous injunction in Smith v. U.S. Department of the Treasury, effectively reinstating FinCEN’s authority to enforce beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA). As a result, reporting companies are once again required to comply with BOI reporting obligations.
However, recognizing the need for additional time, FinCEN has extended the deadline for most companies by 30 days, making the new due date for initial, updated, or corrected BOI reports March 21, 2025. FinCEN has also announced its intent to revise the BOI reporting rule to reduce regulatory burdens, particularly for lower-risk entities such as small businesses.
Entities previously granted later reporting deadlines (e.g., due to disaster relief extensions) must still adhere to their respective timelines. Reporting remains optional for plaintiffs in National Small Business United v. Yellen and its related entities.
For Golenbock’s previous alerts on CTA developments, please refer to them here:
U.S. Supreme Court Stays Preliminary Injunction Against Enforcement of CTA: FinCEN Determines CTA Still Currently Not Enforceable (January 27, 2025)
Corporate Transparency Act – Fifth Circuit Reinstates Nationwide Ban (December 27, 2024)
Corporate Transparency Act Revived: Reporting Companies Have Until January 13, 2025, to Submit Initial BOI Reports (December 24, 2024)
Corporate Transparency Act (CTA) Blocked by Federal Court (December 5, 2024)
Corporate Transparency Act: Rules Requiring Privately Held Companies to Report Beneficial Ownership to the U.S. Government (May 10, 2024)
If you have any questions or need further information, please reach out to your contact at Golenbock or one of the following individuals on the Golenbock CTA FinCEN Compliance Committee:
Contact:
Barry A. Cassell
bcassell@golenbock.com
(212) 907-7337
Jacob L. Chase
jchase@golenbock.com
(212) 907-7362
Sarah E. Kaehler
skaehler@golenbock.com
(212) 907-5680
Maureen R. Monaghan
mmonaghan@golenbock.com
(212) 907-7335
May Shim
mshim@golenbock.com
(212) 622-7161
Golenbock Eiseman Assor Bell & Peskoe LLP
Golenbock Eiseman Assor Bell & Peskoe LLP is a Manhattan-based business law firm with a broad-based practice that offers corporate, complex litigation, labor & employment, real estate, reorganization, intellectual property, tax, and trust & estate expertise. The firm provides high value, sophisticated counsel and representation for its domestic and international clients while maintaining a hands-on, personalized approach to all matters.
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