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February 21, 2025
Updated Status Of Reporting Pursuant To Corporate Transparency Act
The status of BOI (Beneficial Ownership Information) reporting requirements pursuant to the Corporate Transparency Act (CTA) has changed yet again. As a result of a federal District Court opinion issued February 18, 2025 in Texas (Smith, et. al. v. US), the stay on BOI reporting requirements to the FinCEN has been lifted and the new deadline to file an initial, updated, and/or corrected BOI report is now March 21, 2025. As we have previously advised, this reporting obligation currently applies to community association board members.
FinCEN has reported that it will provide updates on any changes to the reporting deadline, as well as its intention to revisit and possibly revise the BOI reporting requirements so as to lessen the burden on lower-risk reporting entities. We will pass along any such updates as they become available.
Further, a bill has been unanimously passed by the U.S. House of Representatives to extend the BOI reporting deadline to January 1, 2026. The U.S. Senate has not yet taken up the bill, which if passed would need the President’s signature to become law.
If you have any questions about the Corporate Transparency Act and the BOI reporting requirements, or any other law affecting community associations, contact any of the lawyers in Hill Wallack’s Community Associations practice group.