Legal Alert by Lamb McErlane PC attorneys Vasilios J. Kalogredis, Esq. and Sonal Parekh, Esq.

On February 18, 2025, the U.S. District Court for the Eastern District of Texas issued a pivotal decision in Smith, et al. v. U.S. Department of the Treasury, et al.[1], effectively reinstating beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA). Because the Department of Treasury (Treasury) acknowledges reporting companies may need additional time to comply with their BOI reporting obligations, the Financial Crimes Enforcement Network (FinCEN) has extended the BOI reporting deadline by 30 days, setting a new deadline of March 21, 2025, for most reporting companies.

Key Updates to BOI Reporting Deadlines

• For the majority of reporting companies, the new deadline to file an initial, updated, or corrected BOI report is March 21, 2025.
• Entities previously granted a deadline later than March 21, 2025, such as those qualifying for disaster relief extensions, should adhere to their original deadlines.
• Specific exemptions remain for plaintiffs involved in National Small Business United v. Yellen, including Isaac Winkles and relevant entities, who are not required to report BOI at this time.

Potential Revisions to BOI Reporting Rules

In line with Treasury’s aim to reduce regulatory burdens, FinCEN is evaluating further deadline modifications and prioritizing reporting requirements for entities posing significant national security risks. Importantly, FinCEN intends to initiate a process this year to revise the BOI reporting rule, potentially easing requirements for lower-risk entities, including many U.S. small businesses.

Background on the Court Decision

This extension follows a series of legal challenges, culminating in the February 18, 2025, decision to stay a previous January 7, 2025, order that had temporarily halted BOI reporting obligations. With the stay now lifted, BOI reporting is mandatory once again, although FinCEN acknowledges the need for additional time for compliance.

Next Steps for Reporting Companies

Reporting companies can submit their BOI information through FinCEN’s E-Filing system, accessible at https://boiefiling.fincen.gov.  As the March 21 deadline approaches, FinCEN is expected to provide updates on any further changes to reporting requirements.

The extension of the BOI reporting deadline and FinCEN’s consideration of rule revisions underscore the evolving regulatory landscape surrounding the CTA. Companies are encouraged to stay informed and consult with legal counsel to ensure compliance with these requirements. For further information, visit FinCEN’s website or contact a legal professional specializing in CTA compliance.

If you have any questions or if we may be of further assistance regarding health law matters, please feel free to contact Bill Kalogredis, Esq. or Sonal Parekh, Esq.

[1] Smith, et al. v. U.S. Department of the Treasury, et al., 6:24-cv-00336 (E.D. Tex.),

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Vasilios J. (Bill) Kalogredis, Esq. has been advising physicians, dentists, and other healthcare professionals and their businesses as to contractual, regulatory and transactional matters for 50 years. He is Chairman of Lamb McErlane PC’s Health Law Department. Bill can be reached by email at bkalogredis@lambmcerlane.com or by phone at 610-701-4402.

 Sonal Parekh, Esq., is an associate at Lamb McErlane PC who focuses on healthcare transactional matters and a broad range of healthcare regulatory-related issues on behalf of healthcare systems, physicians, dentists, and other healthcare providers, and is a pharmacist by education and training. Sonal can be reached by email at sparekh@lambmcerlane.com or by phone at 610-701-4416.

 *This alert is for educational purposes only and is not intended to be legal advice. Should you require legal advice on this topic, any health care matter, or have any questions or concerns, please contact Vasilios J. (Bill) Kalogredis, Esq. or Sonal Parekh, Esq.