CORPORATE TRANSPARENCY ACT NOTICE
ENFORCEMENT BACK IN EFFECT:
NEW DUE DATE OF MARCH 21, 2025
Updated: February 25, 2025
The CTA is back in effect, as of February 18, 2025, with an extended deadline of March 21, 2025, for reporting companies to submit their initial BOI reports. See below for additional information.
On February 18, 2025, the U.S. District Court for the Eastern District of Texas stayed the nationwide injunction against the CTA in the matter of Smith, et al. v. United States Department of The Treasury, et al. Since this was the last remaining active injunction against the CTA, this stay means that the CTA and its reporting requirements are once again in effect as of February 18, 2025.
Non-exempt reporting companies are required to submit their initial BOI reports to FinCEN by March 21, 2025. Limited exceptions apply for reporting companies that qualify for certain disaster relief extensions provided by FinCEN. If you have not yet filed your initial BOI report, you are advised to do so as soon as possible.
In recent statements, FinCEN has indicated that it may modify the reporting requirements of the CTA to "reduce regulatory burdens on businesses." However, until any definitive modifications are announced, reporting companies should continue to submit BOI reports using the CTA's current reporting requirements.
As a reminder, oral arguments in federal appellate court in the matter of Texas Top Cop Shop, Inc., et al. v. Bondi, et al. (formerly Texas Top Cop Shop, Inc., et al. v. Garland, et al.) regarding the constitutionality of the CTA and its reporting requirements will begin on March 15, 2025. Any decision in this matter could ultimately be appealed to the U.S. Supreme Court for final adjudication.
Your Single Solution for Attorney Client Protected FINCen1 Beneficial Owner Compliance!
With a history and focus on government reporting and compliance matters, as well as decades of experience in
tax reporting and compliance, Teeple Hall, LLP is well-positioned to guide Reporting Companies2 through the
complexities of the Corporate Transparency Act (CTA).
For Reporting Companies with simple ownership and management structures, we have developed proprietary
software, the Teeple Hall, LLP CTA Portal, allowing Clients to collect, categorize, submit BOI3 Reports, and maintain audit trails of a Reporting Company’s FinCEN compliance for a modest annual fee.
The Teeple Hall, LLP CTA Portal features provide a secure and managed approach to FinCEN CTA BOI
Reporting under Attorney-Client Privilege, with features as follows:
Provision of 24/7 online access to a customized CTA Portal for each Client/Reporting Company;
Paralegal and/or Attorney review of beneficial ownership documentation submitted into the CTA Portal
by the Reporting Company to validate BOI for conformance with FinCEN submission requirements;
Compilation of BOI data uploaded to the customized CTA Portal into BOI Reports (initial report and
updated reports) for Client/Reporting Company review and secure submission to FinCEN via the CTA
Portal;
Access to Paralegal and/or Attorney staff to answer questions related to CTA definitions and CTA Portal
customer service; and
Maintenance of BOI data and documentation in one web-based, secure location for ease of
management and reference as a FinCEN CTA compliance audit trail.
The Teeple Hall, LLP CTA Portal functionalities have been tailored and developed to assist Clients/
Reporting Companies to navigate the complexities of BOI reporting and the requirements of the CTA,
with functionalities as follows:
Notice of latest CTA news, updates, and revised legislation published by FinCEN via CTA Portal alerts and
automated emails;
Notice of pending expiration dates of BOI identification documents uploaded to the CTA Portal;
Secure upload and storage of Beneficial Owner4 identifying documentation to CTA Portal; and
Secure submission of BOI Reports to FinCEN via the CTA Portal.
The CTA Portal is provided to Clients for an annual fee of $250.00 and includes unlimited BOI Report
submissions to FinCEN during the annual Term5.
Click here to start the engagement process and create your customized CTA Portal page
For more information on Teeple Hall, LLP’s broader range of CTA compliance and reporting
solutions, as well as general information on the Corporate Transparency Act, please click
here.
______________________ 1 “FinCEN” means the Financial Crimes Enforcement Network, a bureau of the United States Department of the
Treasury. 2 Defined in 31 CFR 1010.380(c). 3 Defined in 31 CFR 1010.380(b). 4 Defined in 31 CFR 1010.380(d). 5 “Term” shall have the meaning ascribed to it in the Fee Agreement signed by the Client to commence CTA Portal
services
