Earlier this month, a preliminary injunction temporarily delayed the January 1, 2025, compliance deadline for BOI reporting.
However, the U.S. Court of Appeals for the Fifth Circuit has now reinstated the original deadline. What this means for you is that if you are required to file the BOI and you have not yet done so, you will need to do so NOW.
This means that all reporting companies must submit their BOI to the Financial Crimes Enforcement Network (FinCEN) by January 1, 2025. This date as been extended as follows –
Because the FinCen recognizes that the reporting companies may need additional time to comply given the period when the preliminary injunction had been in effect,” reporting deadlines were extended as follows:
- Reporting companies created or registered before Jan. 1, 2024, have until Jan. 13, 2025, to file initial BOI reports with FinCEN. (These companies would otherwise have been required to report by Jan. 1, 2025.)
- Reporting companies created or registered in the United States on or after Sept. 4, 2024, that had a filing deadline between Dec. 3, 2024, and Dec. 23, 2024, have until Jan. 13, 2025, to file initial BOI reports with FinCEN.
- Reporting companies created or registered in the United States on or after Dec. 3, 2024, and on or before Dec. 23, 2024, have an additional 21 days from their original filing deadline to file initial BOI reports with FinCEN.
- Reporting companies that qualify for disaster relief may have extended deadlines that fall beyond Jan. 13, 2025. These companies should abide by whichever deadline falls later.
- Reporting companies that are created or registered in the United States on or after Jan. 1, 2025, have 30 days to file initial BOI reports with FinCEN after receiving actual or public notice that their creation or registration is effective.
Here is letter we sent out earlier this year regarding the filing. Peck Associates, P.C., does not prepare these filings, you can file them at https://www.fincen.gov/boi. We suggest consulting with legal counsel if you have questions regarding the applicability of the CPTA’s reporting requirements and issues surrounding the collection of the relevant ownership information.