Important BOI Reporting Update: Just the FAQs (Frequently Asked Questions)

Earlier this year, OlenderFeldman LLP notified its clients of the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCen”) requirement that a majority of businesses would be required to disclose their Beneficial Ownership information (“BOI”) under the Corporate Transparency Act (“CTA”).

Q. What has happened?

A. Yesterday, December 3, 2024, the Eastern District of Texas issued an injunction blocking the CTA Nationwide. The Court determined that FinCen does not have jurisdiction to enforce BOI Reporting under the CTA.

Q. What does this mean for BOI Reporting?

A. BOI Reporting is not currently required as a result of the Court’s injunction.

Q. What happens next?

A. In all likelihood, the government will appeal the Court’s injunction.

Q. Do you need to do anything further with respect to BOI Reporting?

A. At this time no further action is required with respect to BOI Reporting, including any BOI Reporting that is in process. OlenderFeldman will advise when there are any updates.

Q. What should you do with your FinCen ID?

A. If you have already obtained a FinCen ID, hold on to it in the event that BOI Reporting is reinstated.