In a Dec. 3 letter to the U.S. Treasury Department and the Financial Crimes Enforcement Network (FinCEN), the COCPA joined the AICPA and other state CPA societies in expressing concern over a prevailing lack of awareness within the small business community regarding the Corporate Transparency Act’s Beneficial Ownership Information (BOI) reporting requirement. 

Further, as the Jan. 1, 2025, filing deadline quickly approaches, the letter urges the delay of the deadline for initial BOI filings by at least one year, to no earlier than Jan. 1, 2026.

“We continue to have grave concerns for the close to 80% of small businesses who have yet to file their BOI information in the FinCEN database,” the letter reads. 

The letter cites among the additional reasons why the filing deadline must be pushed back the constricted timeline for initial filings, staggered delays for areas hit by natural disasters this fall, and several court cases with conflicting outcomes. 

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Breaking news: The most recent of these court case rulings came on Dec. 3, when the U.S. District Court for the Eastern District of Texas suspended the implementation of the BOI reporting requirements. The AICPA is in communication with FinCEN and the U.S. Treasury Department for additional guidance on this injunction.

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Also chief among the reasons why a delay makes sense: growing confusion among financial professionals and the small business community around the program’s basic elements, whose complexity is notably significant for certain entities. 

“There is a definite need for more clarity and simplicity within the program, as well as for the trusted financial professionals who are working to help their clients navigate the reporting requirement,” the letter notes. 

“We urge you to suspend the program for at least one year, during which time you can continue to engage the stakeholder community supporting small businesses and work to better inform small businesses of their reporting requirement. Additionally, we ask that you suspend all enforcement actions throughout any delay,” the letter continues. 

“CPAs are the trusted advisors on whom small businesses rely to navigate complex requirements like BOI filings,” says Alicia Gelinas, CPA, COCPA CEO. “The COCPA is committed to supporting our members in this essential work. By co-signing this letter with the AICPA and other states, we emphasize the need for additional time to raise awareness, secure clearer guidance, and ensure the success of the small business community and the CPAs who serve them — without undue hardship.”

We will continue to monitor developments closely and keep our members informed of any updates. Together, we can work toward a solution that balances transparency with practicality for our professional community.

Click here to read the full letter from the AICPA and other CPA societies, including the COCPA.