Notice to Clients: Updated Deadline for Corporate Transparency Act Filing
Notice originally sent to clients on February 24, 2025
Dear Clients,
As you may be aware, there have been several actions related to the Corporate Transparency Act and enforcement of the requirements to file a Beneficial Ownership Information Report (the “BOIR”) for applicable entities.
Pursuant to the February 18, 2025 decision by the U.S. District Court for the Eastern District of Texas, BOIR requirements are once again back in effect.
For most reporting companies, the new deadline to file an initial, updated, and/ or corrected BOI report is now March 21, 2025. Reporting companies that were previously given a reporting deadline later than the March 21st deadline must file their initial BOI report by that later deadline.
If you have already requested that JRG file a BOIR on your behalf, then we will proceed to file it. If you have not yet confirmed or contacted us about filing a BOIR and you would like assistance, please email trinh@jrgattorneys.com or contact Trinh Retterer at 831-269-7117.
Please be advised that if we do not receive any communication from you on this matter, JRG will not file a BOIR on your behalf.
Notice originally sent to clients on December 26, 2024
The deadline for filing the Beneficial Ownership Information Report ("BOIR") required under the Corporate Transparency Act (CTA) has been extended to January 13, 2025.
On December 23, 2024, the U.S. Court of Appeals for the Fifth Circuit lifted the nationwide preliminary injunction regarding the CTA, which had been issued by the U.S. District Court for the Eastern District of Texas on December 3, 2024. This ruling reinstates the BOIR requirements and associated deadlines.
Updated Filing Deadlines
FinCEN has extended the filing deadlines as follows:
Reporting companies created or registered prior to January 1, 2024: These entities now have until January 13, 2025, to file their initial BOIR with FinCEN.
Note: These companies were previously required to file by January 1, 2025.
Reporting companies created or registered in the United States on or after September 4, 2024, with a filing deadline between December 3, 2024, and December 23, 2024: These entities now have until January 13, 2025, to file their initial BOIR.
Reporting companies created or registered in the United States on or after December 3, 2024, and on or before December 23, 2024: These entities have an additional 21 days from their original filing deadline to submit their initial BOIR to FinCEN.
Reporting companies that qualify for disaster relief: These entities may have extended deadlines that fall beyond January 13, 2025. Such companies should comply with whichever deadline is later.
Reporting companies created or registered in the United States on or after January 1, 2025: These entities must file their initial BOIR with FinCEN within 30 days of receiving actual or public notice that their creation or registration is effective.
Next Steps
If you have already requested our assistance in filing your BOIR, we will proceed accordingly. If you have not yet contacted us but would like us to handle your BOIR filing, please reach out as soon as possible.
You may contact Cat Mineo at cat@jrgattorneys.com.
Please be advised that if we do not receive direct instructions from you on or before January 6, 2024, we cannot guarantee that your filing will be completed prior to the January 13, 2025, deadline.
Thank you for your prompt attention to this matter. If you have any questions or require further clarification, please do not hesitate to contact our office.