March 21, 2025, FinCen update:

On March 21, 2025, FinCEN issued an interim final rule (31 CFR Part 1010.380, RIN 1506-AB49) that exempts all domestic companies from the beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA). Key Points: - Domestic reporting companies are no longer required to file BOI reports with FinCEN. - Companies are not required to update or correct any previously submitted BOI reports. - The definition of "reporting company" has been amended to exclude domestic entities. - This change aligns with Executive Order 14192 emphasizing deregulation and reducing compliance costs.   Legal Justification: The Secretary of the Treasury, with concurrence from the Attorney General and the Secretary of Homeland Security, determined that requiring BOI from domestic companies: - Would not serve the public interest. - Would not be highly useful in national security or law enforcement efforts. Practical Implications: - Domestic companies do not need to file initial or updated BOI reports. - They are no longer considered reporting companies under the CTA. - This change is effective immediately as of the publication date (March 21, 2025). Next Steps: FinCEN is accepting public comments and intends to issue a final rule later in 2025. Domestic companies should monitor further updates but are currently not obligated to take any BOI reporting action.