{"id":13691,"date":"2025-03-03T01:31:54","date_gmt":"2025-03-03T07:31:54","guid":{"rendered":"https:\/\/agrilife.org\/texasaglaw\/?p=13691"},"modified":"2026-04-17T15:09:36","modified_gmt":"2026-04-17T20:09:36","slug":"corporate-transparency-act-reporting-requirements-in-effect-again","status":"publish","type":"post","link":"https:\/\/agrilife.org\/texasaglaw\/2025\/03\/03\/corporate-transparency-act-reporting-requirements-in-effect-again\/","title":{"rendered":"FinCEN Will Not Enforce Corporate Transparency Act Requirements at This Time"},"content":{"rendered":"

Once again, there is a new update related to the status of the Corporate Transparency Act (CTA).<\/p>\n

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Photo by Scott Graham<\/a> on Unsplash<\/a><\/em><\/p><\/div>\n

New Update and Deadline<\/strong><\/p>\n

On Monday, February 17, 2025, the United States District Court for the Eastern District of Texas lifted the nationwide injunction in\u00a0Smith v. U.S. Department of the Treasury<\/em> that prevented the beneficial ownership requirements of the Corporate Transparency Act from going into effect. This was the final nationwide injunction in place pausing the reporting requirements.\u00a0\u00a0In light of this ruling, the United States Department of Treasury Financial Crimes Enforcement Network (FinCEN) initially announced March 21, 2025 as the new deadline for the vast majority of reporting entities to file an initial, updated, or corrected report.<\/p>\n

However, that is not the end of the story.\u00a0 On February 27, 2025, FinCEN issued a press release announcing that it will not issue any fines, penalties, or take any other enforcement actions based on failure to file or update beneficial ownership information.\u00a0 FinCEN will issue an interim final rule no later than March 21, 2025 that will extend reporting deadlines and provide “new guidance and clarity” on the reporting process.\u00a0 [Read press release here<\/a>.]<\/p>\n

On March 2, 2025, the United States Department of the Treasury announced that the new rulemaking will limit the applicability of beneficial ownership reporting only to foreign entities.\u00a0 [Read press release here<\/a>.]<\/p>\n

Basic CTA Information<\/strong><\/p>\n

In January 2024, we began alerting people to the CTA, a new federal law that would require most entities that are created by filings with the Secretary of State (like an LLC, LP, LLP, corporation) to file a beneficial ownership report with FinCEN.<\/p>\n

Who?<\/span><\/p>\n

The reporting requirements apply to most small entities.\u00a0 This includes LLCs, corporations, and any entities created by filing a document with the Secretary of State or other similar agency. This does include single member LLCs.\u00a0 For many states, that includes limited partnerships, limited liability partnerships, and limited liability limited partnerships. Depending on state rules, this may also include certain business trusts.\u00a0 General partnerships and sole proprietorships are not required to report as there is no filing requirement for these entities.<\/p>\n

There are a long list of entities that are exempt from reporting including publicly traded companies, certain tax-exempt entities, certain banks, certain insurance companies, and others.\u00a0 To read more on the exemptions,\u00a0click here<\/a>. Importantly, most farm and ranch entities will likely not fall under the listed exceptions.<\/p>\n

What?<\/span><\/p>\n

There are essentially three categories of information that must be provided:\u00a0 entity information; beneficial owner information; and company applicant information.<\/p>\n

Category 1:\u00a0 Entity information<\/em><\/p>\n

Each entity must report the following information:<\/p>\n