In response to the preliminary injunction against the enforcement of the Corporate Transparency Act granted in Texas Top Cop Shop, Inc, et al. v. Merrick Garland, Attorney General of the United States, et al., the recent stay of such preliminary injunction, and the reinstatement of the requirement for reporting companies to file beneficial ownership information reports, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) has extended the deadline for certain reporting companies to file a beneficial ownership information report.

FinCEN’s revised deadlines for filing beneficial ownership reports are as follows:

• Reporting companies that were created or registered in the United States prior to January 1, 2024 have until January 13, 2025 to file their initial beneficial ownership information reports with FinCEN. (These companies would otherwise have been required to report by January 1, 2025.)
• Reporting companies created or registered in the United States on or after September 4, 2024 that had a filing deadline between December 3, 2024 and December 23, 2024 have until January 13, 2025 to file their initial beneficial ownership information reports with FinCEN.
• Reporting companies created or registered in the United States 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 beneficial ownership information reports with FinCEN.
• Reporting 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.

Please note that the following deadlines to file beneficial ownership information reports have remained unchanged:

• Reporting companies that are created or registered in the United States on or after January 1, 2025 have 30 days to file their initial beneficial ownership information reports with FinCEN after receiving actual or public notice that their creation or registration is effective.
• After an initial beneficial ownership information report is filed and on a going-forward basis, applicable reporting companies will be required to provide updates to FinCEN concerning information covered in the report within 30 days of the date the change occurred.

For more information about the Corporate Transparency Act and its reporting requirements, please visit FinCEN’s website located at www.fincen.gov/boi.