Business and Legal Insights

Shutts & Bowen would like to inform you that earlier this week the U.S. Financial Crimes Enforcement Network (“FinCEN”) announced a temporary postponement of the Beneficial Ownership Information (BOI) reporting deadlines for companies impacted by recent hurricanes and other major storms. This extension aims to alleviate the burden on businesses and individuals grappling with recovery efforts.

If a reporting company (1) has its principal place of business in an area designated both by the Federal Emergency Management Agency (FEMA) as qualifying for individual or public assistance, and by the Internal Revenue Service (IRS) as eligible for tax filing relief as a result of a disaster caused by certain recent named storms, such as Hurricanes Helene and Milton, and (2) has a BOI reporting deadline (whether initial or amended) that falls within a specific window of time (e.g. September 22, 2024 to December 21, 2024 for Hurricane Helene, or October 4, 2024 to January 2, 2025 for Hurricane Milton), then its reporting deadline has been extended by 6 months.

Unlike the reporting period for Hurricane Helene, the affected reporting period for Hurricane Milton includes the January 1, 2025 deadline for all companies that existed prior to 2024. The affected counties are different for each storm, and not all Florida counties are affected, so you are urged to check carefully before delaying your compliance.

Each of the notices from FinCEN is available here:

• NOTICE: FinCEN Provides BOI Reporting Relief to Victims of Hurricane Beryl
• NOTICE: FinCEN Provides BOI Reporting Relief to Victims of Hurricane Debby
• NOTICE: FinCEN Provides BOI Reporting Relief to Victims of Hurricane Francine
• NOTICE: FinCEN Provides BOI Reporting Relief to Victims of Hurricane Helene
• NOTICE: FinCEN Provides BOI Reporting Relief to Victims of Hurricane Milton

For more details on the new reporting deadlines or assistance with compliance, please contact your Shutts attorneys.

This alert is a summary only and is not intended to provide a comprehensive description of the requirements of the Corporate Transparency Act or the BOI reporting requirements. Further information about the CTA requirements can be found at www.fincen.gov/boi.

This alert provides general background information about publicly available material as of the date of this alert. This alert is intended for educational purposes only and does not replace independent professional judgment. Before acting on any information you should consult with legal counsel. The content of this alert is proprietary and confidential and is not intended to be distributed to third parties without the written consent of Shutts & Bowen LLP.