On Feb. 27, FinCEN announced that it will not issue any fines or penalties or take any other enforcement actions against any companies based on any failure to file or update beneficial ownership information (BOI) reports pursuant to the Corporate Transparency Act by the current deadlines.

FinCEN intends to issue an interim final rule no later than March 21 that extends the BOI reporting deadlines.

FinCEN also intends to solicit public comment on potential revisions to existing BOI reporting requirements. Comments will be considered as part of a notice of proposed rulemaking expected to be issued later this year to reduce the regulatory burden on small businesses while ensuring that BOI that is highly useful to important national security, intelligence, and law enforcement activities is reported. FinCEN will also determine what, if any, modifications to deadlines should be considered.

Taft will continue to monitor developments and implications of the CTA and provide additional alerts as information becomes available.