Although a preliminary injunction had previously paused requirements under the Corporate Transparency Act (the “CTA”), a February 18, 2025 decision by the United States District Court for the Eastern District of Texas has reinstated the requirement for certain companies (each, a “Reporting Company”) mandated to continuously report certain “beneficial ownership information” (“BOI”) with the Financial Crimes Enforcement Network (“FinCEN”). Subject to certain exemptions, private fund advisers and the private funds they advise are considered Reporting Companies under the CTA.
In an attempt to address the disruption caused by the injunction, FinCEN has extended certain reporting deadlines:
- Most Reporting Companies must submit their initial reports by March 21, 2025.
- Reporting Companies formed on or after February 18, 2025 are required to file within thirty (30) days of their formation.
Key Takeaway: Reporting Companies, including private funds and their advisers (subject to certain exemptions) should act promptly to meet the extended deadline as set forth above.
Riveles Wahab LLP will continue to monitor developments related to the CTA.
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