The BOI reporting requirement has once again changed. FinCEN recently announced that it “intends to issue an interim final rule that extends BOI reporting deadlines” no later than March 21, 2025. Previously FinCEN announced a March 21, 2025 deadline to file BOI reports.
FinCEN further states “it will not issue any fines or penalties or take any other enforcement actions against any companies based on any failure to file or update beneficial ownership information (BOI) reports pursuant to the Corporate Transparency Act by the current deadlines. No fines or penalties will be issued, and no enforcement actions will be taken, until a forthcoming interim final rule becomes effective and the new relevant due dates in the interim final rule have passed.” In other words, there are no penalties for failing to file a BOI report until a new final rule is issued.
Conclusion
Although FinCEN has not revoked its March 21st deadline to file a BOI report, there is not a penalty for failing to do so. We continue to advise clients not to file a BOI report at this time. We suspect that the CTA may be overturned by the courts or filing requirements will be changed. We will continue to update clients as the BOI reporting requirement evolves.
