CTA NATIONAL UPDATE: FILING DEADLINE REINSTATED WITH DEADLINE EXTENSIONS
As was contemplated, the Fifth Circuit Court of Appeals just reinstated the January 1, 2025, beneficial ownership information filing deadline under the Corporate Transparency Act (CTA) for all community associations. Given this late-breaking federal court development, FinCEN has extended reporting deadlines, including that reporting companies that were created or registered prior to January 1, 2024 have until January 13, 2025 to file their initial beneficial ownership information reports with FinCEN.
Given this late-breaking federal court development, FinCEN has extended reporting deadlines as follows:
- Reporting companies that were created or registered prior to January 1, 2024 have until January 13, 2025 to file their initial beneficial ownership information reports with FinCEN.
- Reporting companies created or registered in the United States on or after September 4, 2024 that had a filing deadline between December 3, 2024 and December 23, 2024 have until January 13, 2025 to file their initial beneficial ownership information reports with FinCEN.
- Reporting companies created or registered in the United States on or after December 3, 2024 and on or before December 23, 2024 have an additional 21 days from their original filing deadline to file their initial beneficial ownership information reports with FinCEN.
This continues to be a developing matter, but at the time of this communication applicable community associations should proceed to file their BOI reports in compliance with their applicable FinCEN deadline extension.
Time is now dangerously short. If you have not yet registered and need assistance. Contact your attorney or account or any of the third party company applicants to get into compliance. As a reminder, here is what is required to file the BOI report:
- Each Board member’s full name
- Each Board member’s date of Birth
- Each Board member’s address
- A copy of each Board member’s unexpired passport or license
- The tax Id no. for the Association
From everyone at Bender, Anderson and Barba, we wish you all a Merry Christmas, a Happy Hanukkah and the happiest of New Years