On December 3, 2024, a federal court issued a nationwide injunction temporarily halting enforcement of the CTA's Beneficial Ownership Information (BOI) reporting deadline of January 1, 2025 – as well as suspending the enforcement of penalties. This decision is not final – and an appeal has already been filed by the United States Department of Justice on behalf of the US Treasury and FinCEN.
FinCEN has announced they will comply with the court order for as long as it remains in effect. Therefore, reporting companies are not presently required to file their beneficial ownership information and will not be subject to liability if they fail to do so while the preliminary injunction remains in effect.
Furthermore, FinCEN has notified all 3rd party service providers (including SnapBOI) that, effective immediately, transmission of BOI reports to FinCEN will not be accepted.
Despite the uncertainty, we recommend proceeding with preparation of BOI filings. If the injunction is overturned, compliance may be required quickly, and early filing can help avoid penalties or last-minute stress.
Your firm’s access, as well as your client’s access, to the SnapBOI platform will remain active. Until further guidance is provided, actual payment for reports and filing with FinCEN will be temporarily suspended. During this period of uncertainty, support will be limited to the SnapBOI knowledgebase and our chatbot.
Team SnapBOI thanks you for your confidence and will provide further updates when available.