By Tom Murray

On February 18, 2025, the US Treasury’s Financial Crimes Network (FinCeN) released the following statement, setting a new March 21st deadline to file Beneficial Ownership Information (BOI) reports:

With the February 18, 2025, decision by [a U.S. District Court in Texas], beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA) are once again back in effect. However, because the Department of the Treasury (Treasury) recognizes that reporting companies may need additional time to comply with their BOI reporting obligations, FinCEN is generally extending the deadline 30 calendar days from February 19, 2025, for most companies.

Notably, in keeping with Treasury’s commitment to reducing regulatory burden on businesses, during this 30-day period FinCEN will assess its options to further modify deadlines, while prioritizing reporting for those entities that pose the most significant national security risks. FinCEN also 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.

Updated Deadlines - For the vast majority of reporting companies, the new deadline to file an initial, updated, and/or corrected BOI report is now March 21, 2025. FinCEN will provide an update before then of any further modification of this deadline, recognizing that reporting companies may need additional time to comply with their BOI reporting obligations once this update is provided.

Thus, AS OF NOW, the Board members of Indiana homeowners associations and condominiums associations must file the BOI reports by March 21, 2025. In light of the many twists and turns that the CTA has taken due to numerous court challenges, that date could be extended, but that is far from a certainty!

Meanwhile, there are pending bills in the US House of Representatives and the US Senate that, if passed, would extend the filing deadline to January 1, 2026.

What should the Association’s Board Members do?

We recommend that Board members of Indiana homeowners associations and condominium associations file the BOI reports with FinCEN fairly soon and not wait until the “last minute” to file them prior to the newly established March 21st deadline.  FinCEN’s website has helpful information on how to file:  www.fincen.gov/boi  

 Stay tuned for more information.

We will continue monitoring the CTA and will provide information as the legal landscape surrounding the CTA evolves.

If you would like to discuss these or other issues with our firm, please contact one of our firm’s attorneys directly or email us through the firm’s website at info@IndianaHOALaw.com