Corporate Transparency Act is back, with new March 21 filing deadline

FAYETTEVILLE — The Corporate Transparency Act, a law aimed at combating financial crime, is back in play with a new filing deadline after federal district judge lifted a stay he imposed last month.
“Since the stay has been lifted, the CTA is again enforceable,” said Elizabeth Rumley, a senior staff attorney at the National Agricultural Law Center. The law is enforced by FinCEN, the federal Financial Crimes Enforcement Network, part of the U.S. Treasury Department. “FinCEN has set a new deadline of March 21 for the majority of reporting companies.”
On Monday, Judge Jeremy Kernodle of the Eastern District of Texas lifted the stay he put in place Jan. 7.
Elizabeth Rumley
Elizabeth Rumley of the National Agricultural Law Center gives the latest in the switchback journey of CTA through the courts. (U of A System Division of Agriculture photo)
The Corporate Transparency Act is a federal law aimed at combating financial crimes such as money laundering and tax evasion. Under the CTA, most corporations, limited liability companies and similar entities are required to disclose their “beneficial owners”—individuals who own or control at least 25 percent of the business or exercise significant decision-making authority, Rumley said.
Congressional action
While the case wends its way through the courts, the U.S. House and Senate are also looking at CTA and have put forth several bills to modify the deadlines or eliminate CTA altogether.

On Feb. 10, the U.S. House unanimously passed H.R. 736, which would extending CTA’s filing deadline until Jan. 1, 2026. The proposal has moved to the Senate for consideration. The Senate is also considering S. 505, which would also modify the deadline for filing beneficial ownership information reports for reporting companies formed or registered before Jan. 1, 2024.
These House and Senate bills would postpone the deadline but leave the reporting requirements intact.
Other legislation, introduced as H.R. 125 and S. 100, the “Repealing Big Brother Overreach Act,” would repeal the CTA entirely. The bills are under committee consideration in their respective chambers.
Internal review
FinCEN has also said it “intends to initiate a process this year to revise the BOI reporting rule to reduce burden for lower-risk entities, including many U.S. small businesses.”
Changes could be made based on further developments as the law progresses through the courts, or changes in the regulations or guidance or even further Congressional action.
“Because of that, it is important to stay aware of future developments,” Rumley said.