By: Trev E. Peterson
On December 23, 2024 the Fifth Circuit Court of Appeals granted a stay of the preliminary injunction enjoining enforcement of the beneficial ownership reporting regulations issued earlier this month by the District Court for the Eastern District of Texas. All of this means that reporting companies have to complete the required beneficial interest reporting. However given the issuance of the preliminary injunction by the federal court in Texas, the January 1, 2025 deadline has been extended as follows:
Reporting companies created or registered prior to January 1, 2024 have until January 13, 2025 to file their initial reports.
Reporting companies created or registered on or after September 4, 2024 that had a filing deadline between December 3 and December 23, 2024 have until January 13, 2025 to file their initial reports.
Reporting companies that were filed between December 3, 2024 and December 23, 2024 have an additional 21 days to file their initial reports.
Reporting companies that qualify for disaster relief may have extended deadlines that fall beyond January 13, 2025, if so those companies should file on the later of the extended deadline of January 13, 2025.
Remember that any reporting company formed after January 1, 2025 has only 30 days to file its initial beneficial ownership report.
The author recommends that all reporting companies file their beneficial ownership reports as soon as possible, and certainly by January 13, 2025.