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On Sunday, the Treasury Department issued yet another announcement on the enforcement and future of the beneficial ownership information reporting under the Corporate Transparency Act (CTA). The announcement notes:

The Treasury Department is announcing today that, with respect to the Corporate Transparency Act, not only will it not enforce any penalties or fines associated with the beneficial ownership information reporting rule under the existing regulatory deadlines, but it will further not enforce any penalties or fines against U.S. citizens or domestic reporting companies or their beneficial owners after the forthcoming rule changes take effect either. The Treasury Department will further be issuing a proposed rulemaking that will narrow the scope of the rule to foreign reporting companies only. Treasury takes this step in the interest of supporting hard-working American taxpayers and small businesses and ensuring that the rule is appropriately tailored to advance the public interest.

“This is a victory for common sense,” said U.S. Secretary of the Treasury Scott Bessent. “Today’s action is part of President Trump’s bold agenda to unleash American prosperity by reining in burdensome regulations, in particular for small businesses that are the backbone of the American economy.”

Sunday’s announcement represents the third major development with the CTA in just the past two weeks! As Meredith noted on February 20, FinCEN had announced that beneficial ownership information reporting requirements under the CTA were back in effect following key court developments, with a new deadline of March 21, 2025 for most companies. Then, on February 27, FinCEN announced that it would not issue any fines or penalties or take any other enforcement actions against any companies based on any failure to file or update beneficial ownership information reports pursuant to the Corporate Transparency Act by the current deadlines, while also seeking to issue a new interim final rule that would extend the BOI reporting deadlines and solicit public comment for potential revisions to existing BOI reporting requirements.

It is understandable if you are feeling a bit of whiplash given all of the CTA developments that have played out over the past few weeks and months. At this point, it appears that at least some entities can go “pencils down” on their beneficial ownership information reporting under the CTA, and you can follow the forthcoming developments in our “Beneficial Ownership” Practice Area.

– Dave Lynn