February 19, 2025

Following the February 18, 2025 decision by the U.S. District Court for the Eastern District of Texas in Smith v. U.S. Department of the Treasury, et al., 6:24-cv-00336, the Financial Crimes Enforcement Network (FinCEN) has announced that the beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act are back in effect, with a new deadline of March 21, 2025 for most companies.

FinCEN has also announced it will assess its options to further modify deadlines, while prioritizing reporting for those entities that pose the most significant national security risks. FinCEN intends to initiate a process this year to revise the BOI reporting rule to reduce burden for lower-risk entities, including many U.S. small businesses.

Bottom Line: The nationwide injunction entered in Smith v. U.S. Department of the Treasury is no longer in place and, as a result, condominium, townhome and homeowner associations must file their BOI reports with FinCEN no later than March 21, 2025.

This remains a developing issue that BARRY LAW, INC. will continue to closely monitor and shall provide updates as developments become available.

If you have any questions about the CTA or wish to voluntarily file yours at this time, you may contact BARRY LAW, INC. at (773) 779-6100, or by email at info@barrylawinc.com

Further information regarding this development can be accessed here: https://www.fincen.gov/sites/default/files/shared/FinCEN-BOI-Notice-Deadline-Extension-508FINAL.pdf