An Updated Timeline of BOI Reporting Requirements

Recent legal developments have impacted the enforcement of beneficial ownership reporting requirements under FinCEN regulations. The case of Texas Top Cop Shop, Inc. v. Garland has resulted in a series of court decisions, affecting the obligations of reporting companies. Below is a timeline of the key rulings and FinCEN's responses to these changes.

December 23, 2024: A panel of the U.S. Court of Appeals for the Fifth Circuit granted a stay of the district court’s preliminary injunction in Texas Top Cop Shop, Inc. v. Garland. This stay allowed the Department of the Treasury to proceed with its appeal of the district court’s order. Following the ruling, FinCEN issued an alert to the public and extended reporting deadlines to accommodate potential delays in compliance with beneficial ownership reporting requirements.

December 26, 2024: A different panel of the same court vacated the December 23 stay order, reinstating the district court’s preliminary injunction. As a result, the injunction remains in effect, and reporting companies are not currently required to file beneficial ownership information with FinCEN.

The decision is not final and is subject to change. Updated information will be posted when made available. If you would like to read more, please visit FinCEN’s page on BOI.

Don’t hesitate to contact us if you have any questions regarding BOI filing, we’re here to help!