Until recently, FinCEN made BOI Reports voluntary. However, FinCEN has changed course and announced a March 21, 2025 deadline to file BOI Reports.
We will contact clients for necessary information to file their BOI Reports if we do not have such information. However, unless a client instructs us to do otherwise, we will not process BOI Reports until the week of March 17th.
We believe it is possible that any deadline or requirement to file the BOI Reports may change prior to March 21st.
The reason for such belief is three-fold:
- As previously shared in our prior BOI update, we believe the Trump administration will not vigorously defend the pending lawsuits challenging the constitutionality of the Corporate Transparency Act (CTA), which requires the BOI Reports. President Trump vetoed the CTA legislation when he was in office previously. Therefore, it is reasonable to suspect the Department of Justice will curtail its defense of the CTA under the Trump administration.
- On January 15, 2025, the Repealing Big Brother Overreach Act (H.R. 425) was reintroduced to the U.S. Senate and House of Representatives. If passed, the bill repeals the CTA.
- On February 10, 2025, the House of Representatives also introduced the Protect Small Businesses From Excessive Paperwork Act of 2025. Such legislation would extend the deadline to file BOI Reports to January 1, 2026.
Conclusion
We will file BOI Reports prior to the March 21st deadline, but will not commence until the week of the deadline. If the BOI requirement or reporting deadline changes, we will update clients
