Corporate Transparency Act (CTA) Compliance: Reporting Requirements Have Resumed

Corporate Transparency Act (CTA) Compliance: Reporting Requirements Have Resumed
As of February 18, 2025, both previously-effective nationwide injunctions which stopped enforcement of the Corporate Transparency Act (CTA) have been “stayed” (i.e., paused). As a result, the requirement for companies to file Beneficial Ownership Information (BOI) reports with the Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) is once again mandatory.
 
Any business that is subject to the CTA will be required to disclose certain personal information about its beneficial owners, and FinCEN is tasked with collecting and maintaining this information. Compliance with the CTA remains a requirement for many small businesses throughout the United States.
 
If you have an entity that is not exempt from CTA compliance, that entity is required to file BOI reports with FinCEN: 
 

• If your business was created prior to February 18, 2025, you have until March 21, 2025, to file this report. 

• If your business was created after February 18, 2025, you have until 30 days after forming your business to file this report. 

• If either your business or one/more of its Beneficial Owners experiences a change in reportable information (for example, a change of address), you have until 90 days after that change occurs to file an updated report.

 
However, it is best to file these reports sooner rather than later. If either your initial BOI Report (or an updated BOI Report) is not filed on time, you may be subject to a $500 per day civil penalty, a fine of $10,000 and imprisonment for up to two years. 
 
You can have our office prepare and file this report on your Company’s behalf. Alternatively, you may file this information yourself by going to https://boiefiling.fincen.gov/fileboir, filling out the report and submitting it online. 
 
If you would like our office to complete CTA reporting for you (or if you have any questions or concerns regarding CTA compliance), please contact your Bradley & Riley attorney (or our Firm’s Business Practice Group via email at: CTA@bradleyriley.com).