On again: Transparency Act requirement is back
The Corporate Transparency Act and its requirement that businesses file beneficial ownership information with the Financial Crimes Enforcement Network, is on again.
After a Texas judge lifted an injunction that had halted the reporting requirements, businesses are now expected by law to comply—provide information about who owns the business—by March 21.
In the latest development and following the judge’s latest ruling, the FinCEN issued guidance Feb. 19 including: “For the vast majority of reporting companies, the new deadline to file an initial, updated, and/or corrected BOI report is now March 21, 2025. FinCEN will provide an update before then of any further modification of this deadline, recognizing that reporting companies may need additional time to comply with their BOI reporting obligations once this update is provided.”
Objection to the rule has come from business groups concerned with the additional paperwork, and potential for fines for non-compliance (up to $591 per day, and for willful violators up to $10,000).
According to the National Lumber and Building Material Dealers Association, the new guidance from FinCEN implies that the deadline may be amended before March 21. Additionally, the new administration has signaled a desire to reduce regulatory burdens placed on small businesses and have indicated that exemptions may be coming for “lower-risk entities,” the NLBMDA said.
Against the backdrop of the off-again, on-again paperwork requirement of the CTA, the U.S. House passed the Protect Small Business from Excessive Paperwork Act of 2025 (H.R.736), a bill that would delay CTA reporting requirements until January 1st, 2026.
According to the NLBMDA, which is supporting the bill, Senate Banking Committee Chairman Tim Scott (R-SC) is leading the effort on the Senate side to pass this legislation. So far, the legislation still remains with the Senate Banking Committee and a vote has not been scheduled.