On February 18, 2025, the United States District Court for the Eastern District of Texas lifted a nationwide preliminary injunction that prevented Corporate Transparency Act (“CTA”) enforcement, allowing the Financial Crimes Enforcement Network (“FinCEN”) to reinstate the CTA’s beneficial ownership reporting obligations. Immediately following the decision, FinCEN issued a statement extending the CTA’s reporting deadline until March 21, 2025, for non-exempt reporting companies formed prior to February 19, 2025. Non-exempt reporting companies formed after February 19, 2025, have thirty days to file their beneficial ownership reports.
Despite the reinstated reporting deadline, there are several ongoing legislative efforts to delay or repeal the CTA entirely. For instance:
- The “Protect Small Businesses from Excessive Paperwork Act of 2025” unanimously passed the House of Representatives on February 10, 2025. The bill would extend the CTA’s reporting deadline until January 1, 2026, and is under review by the Senate Committee on Banking Housing, and Urban Affairs.
- The “Repealing Big Brother Overreach Act” was recently introduced in the House of Representatives and Senate. The bill aims to repeal the CTA’s beneficial ownership reporting obligations altogether.
Although each bill has gained initial support, there is no guarantee that either will become law prior to the March 21, 2025, reporting deadline. Therefore, we strongly advise clients to gather the information required to complete their beneficial ownership reports as soon as possible. All prior Hall Render articles related to the Corporate Transparency Act can be referenced here.
Next Steps
Non-exempt reporting companies should consider seeking professional guidance from an attorney to ensure compliance with the CTA’s beneficial ownership reporting obligations. Given the substantial penalties for failure to comply, entities subject to the CTA should begin collecting the information required to be reported as soon as possible.
Hall Render will continue to monitor and provide updates related to the CTA. If you have any questions or would like additional information about this topic, please contact:
- John Bowen at jbowen@hallrender.com or (317) 429-3629;
- Eric Speer at espeer@hallrender.com or (317) 741-0661; or
- Your primary Hall Render contact.
Hall Render blog posts and articles are intended for informational purposes only. For ethical reasons, Hall Render attorneys cannot—outside of an attorney-client relationship—answer specific questions that would be legal advice.
