Most Reporting Companies Must File by March 21, 2025

If you are having trouble keeping track of the developments in beneficial ownership information (“BOI”) reporting, you are not alone. Since early December, the reporting requirements have been in effect, have been stayed, have been in effect, again, and have been stayed, again. Now the requirements are back in effect, again, and this time it looks like the requirements may be here to stay, at least for awhile.

On January 7, 2025, the U.S. District Court for the Eastern District of Texas, in a case called Smith, et. al, v. U.S. Department of the Treasury, et. al., issued an order that prevented FinCEN (the agency handling BOI reporting) from enforcing the BOI reporting requirements. This order was appealed, and, yesterday, the court agreed to stay its January 7th order until that appeal is completed. This means that the order that prevented enforcement of the BOI reporting requirements is no longer in effect, and, yesterday, FinCEN issued a notice that it does, in fact, intend to enforce those requirements. (The full text of the FinCEN notice can be found here: FinCEN Notice.)

What does this mean for your company? According to FinCEN’s notice, most reporting companies will need to file their initial, updated and/or corrected BOI reports with FinCEN by March 21, 2025. Reports can be e-filed at https://boiefiling.fincen.gov. There is no charge for filing these reports. Note that there are many nongovernmental websites out there with good search engine optimization that appear to be the place to file your BOI report, or that may offer to help you file your report, for a fee. In order to protect your company’s confidential information (and to avoid paying any unnecessary fees), we recommend that you file your report directly with FinCEN.

This article was written by Janice L. Gauthier, Esq. Ms. Gauthier has an A.B., cum laude, from Harvard University and a J.D, cum laude,. from Harvard Law School.  She is a business and real estate lawyer and the owner of The Gauthier Law Group, LLC, a boutique business and real estate law firm that represents dentists, physicians, optometrists, chiropractors, veterinarians, and other health care providers in business and real estate transactions in the Greater Milwaukee, Chicago and Madison Areas, as well as in other parts of Wisconsin and Illinois.  You can contact Ms. Gauthier at 414-270-3855, ext. 101 or by email.

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