Significant Update on Corporate Transparency Act

Beneficial Ownership Information Reporting (BOIR) Requirements

In a major development affecting compliance with the Corporate Transparency Act, beneficial ownership information reporting (BOIR) is once again mandatory. This follows a key legal decision in which the 5th Circuit Court of Appeals lifted the nationwide preliminary injunction previously issued by the U.S. District Court for the Eastern District of Texas that had paused FinCEN’s enforcement of BOIR obligations.

FinCEN’s Response and Updated Deadlines of BOIR

In light of the appellate court’s decision, FinCEN has promptly updated its guidance and extended several filing deadlines. All reporting companies subject to these requirements must now meet the revised deadlines outlined below. For any further questions or clarification, contact Truck Owners and Drivers Association.

• Updated BOIR Deadlines (Effective December 24, 2024)
  • Entities Registered Prior to January 1, 2024
    Companies created or registered before January 1, 2024, are now granted until January 13, 2025 to submit their initial beneficial ownership information reports. (Originally, these companies were required to file by January 1, 2025.)

• • Entities Registered On or After September 4, 2024
    Companies that were created or registered in the United States on or after September 4, 2024—with an initial filing deadline set between December 3, 2024, and December 23, 2024—also have until January 13, 2025 to complete their reporting.

• • Entities Registered Between December 3, 2024, and December 23, 2024
    These companies are provided with an additional 21-day extension beyond their original filing deadline to file their initial reports with FinCEN.