The FinCEN Beneficial Ownership Rule saga has written another chapter. You can review our last update on our website. 

This information is accurate as of February 19th, 2025 at 3 p.m.  

On February 18, 2025 the decision in Smith, et al. v. U.S. Department of the Treasury, et al, means that the beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA) are once again back in effect.  

Yes, the reporting requirements are back in effect.  

The U.S. Department of Treasury has recognized that due to the tumultuous history with the rule that companies may need additional time to comply with this reporting requirement.  

The reporting requirement date is now March 21, 2025. This is unless you had received an extension for reporting. You would have needed to request an extension and received one from the Treasury Department.  

And as a reminder from our previous update, a real estate firm that is a corporation or LLC would be required to report. Basically, if you created your company by filing a document with a secretary of state, then you most likely are required to report. If you are a sole proprietor and you did not create the proprietorship by filing a document with a secretary of state or similar office, then you are not a reporting company. 

Reporting companies can report their beneficial ownership information directly to FinCEN, free of charge, using FinCEN’s E-Filing system available at https://boiefiling.fincen.gov. More information is available at https://fincen.gov/boi.