On February 18, 2025, the U.S. District Court for the Eastern District of Texas issued an Order in the Smith case lifting the preliminary injunction against enforcement of the CTA. Therefore, BOI Report filings are once again mandatory. FinCEN has extended the deadline to file an initial, updated, and/or corrected BOI for most companies to March 21, 2025. The Alert from FinCEN can be found here.
As indicated by FinCEN, we expect more changes to come, but we do not know what they are or who they will affect. The changes will likely include further extended deadlines and possibly limit who needs to file. We will issue an updated alert once further information is available.