Guidance on CTA BOI Filing Deadlines

The Financial Crimes Enforcement Network (FinCEN) just announced this evening that it will relax the CTA’s BOI filing deadline beyond January 1, 2025.  The deadline was not changed by the courts or Congress, but basically FinCEN is communicating that it will not start enforcing penalties for late filings until January 13, 2025.  Therefore, we encourage everyone to get their outstanding BOI reports uploaded into FinCEN no later than January 12, 2025.  If anything changes again, we will be sure to alert you.  Here is a summary of the new deadlines, which can also be found at https://www.fincen.gov/boi:

Dear Speaker Johnson, Minority Leader Jeffries, Majority Leader Schumer, and Minority Leader McConnell:

• Companies that were created prior to January 1, 2024 have until January 13, 2025 to file their initial reports with FinCEN. (These companies would otherwise have been required to report before January 1, 2025 given today’s court decision.)
• Companies created on or after September 4, 2024, that had a filing deadline between December 3, 2024 and December 23, 2024, now have until January 13, 2025 to file their initial reports with FinCEN.
• Companies created on or after December 3, 2024 and on or before December 23, 2024, have an additional 21 days from their original filing deadline to file their initial reports with FinCEN.
• Companies that qualify for disaster relief may have extended deadlines that fall beyond January 13, 2025. These companies should abide by whichever deadline falls later.
• Companies that are created on or after January 1, 2025 have 30 days to file their initial reports with FinCEN.