I’ve written in the past here and here about the whipsaw court rulings on whether reporting is or is not required. On January 23, 2025, the United States Supreme Court weighed in. It lifted the trial court’s injunction preventing the FinCEN from requiring the beneficial reporting.

Noting the neck pain the various court rulings was causing observers, the FinCEN issued guidance that it is not currently enforcing the the requirements of the reporting rule against any individual or entity. Reporting companies are, therefore, not currently required to file beneficial ownership information with FinCEN. Reporting companies may continue to voluntarily submit beneficial ownership information reports.

Notwithstanding the pending litigation and FinCEN’s current stance on filing requirements, entities affected by Hurricane Milton, the filing deadline was extended to on or before July 1, 2025.

            The Florida counties benefiting from this 6 month extension are –

• Brevard, Charlotte, Citrus, Collier, DeSoto, Duval, Flagler, Glades, Hardee, Hendry, Hernando, Highlands, Hillsborough, Indian River, Lake, Lee, Manatee, Marion, Okeechobee, Orange, Osceola, Palm Beach, Pasco, Pinellas, Polk, Putnam, Sarasota, Seminole, St. Johns, St. Lucia, Volusia.

If you are in one of the affected counties, the deadline for reporting will be no earlier than July 1, 2025.