FinCEN is as sick of the CTA as you all are. Yesterday, they announced that no fines, penalties, or other enforcement action will occur for the failure to file a BOI report while they figure out what the heck they’re doing with the CTA and new rulemaking. We should have more information on what those rules will look like – maybe a common interest community exemption? – by March 21. Until then, go ahead. Break the law. Don’t file. Or do. I won’t tell.
