Client Notice: Corporate Transparency Act Filing Requirement Reinstated

On February 18, 2025, a federal court took action that reinstates the requirement that all reporting companies subject to the Corporate Transparency Act’s (CTA) filing requirement that have not already filed a Beneficial Ownership Information Report (BOIR) under the Act are once again required to file.

The Financial Crimes Enforcement Network (FinCEN) has announced that the deadline for filing a BOIR for nearly all reporting companies is March 21, 2025. The sole exception is for the small number of reporting companies with an original filing deadline later than March 21, 2025. Their filing deadlines remain unchanged. FinCEN noted that it will assess its options to further modify deadlines, while prioritizing reporting for those entities that pose the most significant national security risks.

McLane Middleton will resume compiling reporting information and submitting BOIRs on behalf of client reporting companies that paused while the filing requirement was suspended. Any client reporting company that initially requested that McLane Middleton proceed on its behalf, but that no longer wishes for our firm to do so, must notify us by email or other writing, or by speaking directly with a McLane Middleton attorney.

Court cases challenging the constitutionality of the CTA are pending in multiple courts across the country. Additionally, there are Congressional efforts to extend filing deadlines, limit the scope of the CTA, or repeal the CTA. McLane Middleton will monitor these developments, and issue notices if significant changes occur.

If you have questions about the reinstated filing requirement, please contact your McLane Middleton attorney or attorney Tony Delyani at (603) 334-6935 or tony.delyani@mclane.com.