February 6, 2025: As you are likely aware, the Corporate Transparency Act (CTA) requires certain businesses to disclose their beneficial owners—the individuals who control or own the business—to the Financial Crimes Enforcement Network (FinCEN).  This includes most owners Associations, including residential and commercial associations.

Over the past year the CTA has been subject to many legal battles, and as a result there has been an incredible amount of confusion over whether or not reporting is required.  In an effort to provide the most information possible, below is a brief timeline of what has happened over the past two months.

  • 12/3/24: A federal court in Texas halted the enforcement of CTA’s reporting requirements nationwide, ruling that the CTA and its reporting provisions were likely unconstitutional.
  • 12/10/24: Following the Texas ruling, FinCEN announced that companies were not subject to liability if they failed to meet the January 1, 2025, reporting deadline.
  • 12/23/24: The government appealed the Texas ruling, and the 5th Circuit Court granted an emergency motion lifting the nationwide injunction.
  • 12/24/24: FinCEN extended the reporting deadline to January 13, 2025
  • 12/26/24: The 5th Circuit vacated its stay issued on 12/23/24, and the preliminary injunction was once again in effect.
  • 12/27/24: FinCEN announced that, due to the ongoing federal court order, reporting companies are currently not required to file beneficial ownership information and no deadline was being enforced.
  • 01/23/25: The Supreme Court lifted the nationwide injunction on the CTA, allowing enforcement to proceed.
  • 01/24/25: Despite the Supreme Court’s action, a separate injunction (issued on 1/7/25) remains in effect. Reporting companies are not subject to liability if they fail to file.
  • 2/6/2025: On February 5, 2025, the Department of Justice, on behalf of the Department of the Treasury, filed a notice of appeal against the district court’s injunction and requested a stay of the order while the appeal is pending in Smith v. U.S. Department of the Treasury, No. 6:24-CV-336 (E.D. Texas 1/7/25).
  • 2/19/2025: BOI Filings are mandatory again.  New deadline is March 21, 2025.
  • On February 18, 2025, the U.S. District Court for the Eastern District of Texas granted a stay on the second injunction, allowing full enforcement of the Corporate Transparency Act.  FinCEN confirmed that the new deadline is March 21, 2025.  Additionally, potential penalties have now been increased to $606 per day for willful non-compliance.
  • 2/28/25 – UPDATE: Temporary Suspension of Fines and Penalties 
  • FinCEN will not enforce fines or penalties for current BOI reporting deadlines.
  • A new interim final rule is expected by 3/21/25
  • FinCEN has stated that the interim final rule will include extended reporting deadlines.
  • For more information: https://fincen.gov/news/news-releases/fincen-not-issuing-fines-or-penalties-connection-beneficial-ownership
  • March 2, 2025 – U.S. Treasury suspends enforcement of the Corporate Transparency Act (CTA) for U.S. citizens and domestic entities.
  • Treasury will not enforce penalties for noncompliance and plans to limit the CTA to foreign reporting companies only.
  • CTA Review has paused collection efforts for outstanding information.
  • CTA Review will continue filing BOI reports by request only. To proceed, contact natalie@ctareview.com
  • Due to ongoing regulatory changes, CTA Review will retain information until FinCEN/Treasury issues a final ruling.
  • March 2, 2025 – U.S. Treasury suspends enforcement of the Corporate Transparency Act (CTA) for U.S. citizens and domestic entities.