Mandatory filing requirements for the Corporate Transparency Act (“CTA”) are on again as of this week. The new deadline for compliance is March 21, 2025.
On February 18, 2025, the United States District Court for the Eastern District of Texas granted the government’s motion to stay the nationwide injuncting halting enforcement of the Corporate Transparency Act in the case of Smith v. U.S. Department of the Treasury. This was the last remaining nationwide order pausing CTA filing requirements. Based on this new order, CTA reporting requirements for homeowner and condominium association boards of directors are now reinstated.
Following the Texas court’s ruling, FinCEN issued the following statement:
[B]eneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA) are once again back in effect. However, because the Department of the Treasury recognizes that reporting companies may need additional time to comply with their BOI reporting obligations, FinCEN is generally extending the deadline 30 calendar days from February 19, 2025, for most companies.
FinCEN also noted that “in keeping with Treasury’s commitment to reducing the regulatory burden on businesses, during this 30-day period FinCEN will assess its options to further modify deadlines, while prioritizing reporting for those entities that pose the most significant national security risks.
NowackHoward continues to closely monitor the litigation and legislation involving the Corporate Transparency Act. The Community Associations Institute also continues to track the various CTA litigation. Visit CAI’s Corporate Transparency Act webpage for ongoing updates and advocacy efforts and opportunities.
For our clients who requested NowackHoward assistance with their CTA filing, we will be reaching out next week to confirm that you would like us to process your report. If your Association has not yet filed its report and would like our assistance, please email CTA@nowackhoward.com. You can also file your Association’s report directly with FinCEN through the BOI FinCEN Portal.
