On January 31, 2025, President Trump issued Executive Order 14192, Unleashing Prosperity Through Deregulation, which announced an Administration policy “to significantly reduce the private expenditures required to comply with Federal regulations to secure America’s economic prosperity and national security and the highest possible quality of life for each citizen” and “to alleviate unnecessary regulatory burdens placed on the American people.”
In line with this policy, on March 26, 2025, the Department of Treasury issued an interim final rule under the Corporate Transparency Act (CTA) that significantly narrows the scope of beneficial ownership information (BOI) reporting requirements. Specifically, the rule limits BOI reporting to only “foreign reporting companies” and non-U.S.-person beneficial owners. This interim final rule removes all “domestic reporting companies” and U.S. persons from the scope of BOI reporting under the CTA.
In issuing the interim final rule, the Secretary of the Treasury considered alternative sources of information to mitigate illicit finance risks, such as the continuing requirement for covered financial institutions to collect a legal entity customer’s BOI at the time of account opening. Notably, this interim final rule does not impose any new obligations but rather exempts domestic reporting companies and U.S. persons who are beneficial owners of foreign reporting companies from the CTA reporting requirements.
The public comment period for the interim final rule ended on May 27, 2025. A final rule is expected to be issued by the Department of Treasury before year end.
Attorneys at Wolfson Bolton Kochis PLLC continue to closely monitor developments related to the CTA’s implementation. Please contact Amy H. Smith (asmith@wolfsonbolton.com) for more information.
