FinCEN Announces Filing Relief for Reporting Companies Impacted by Hurricanes

On October 29, 2024, FinCEN announced that certain reporting companies impacted by Hurricanes Beryl, Debby, Francine, Helene, and Milton will be granted an additional six months to submit beneficial ownership information reports. This relief encompasses initial reports as well as updates and corrections.  

Qualified reporting companies must have due dates that fall within a specified time period for each hurricane and must have a principal place of business in an area designated both by FEMA and the IRS as qualifying for each agency’s respective relief. If the IRS designates more areas as qualifying for tax filing relief, FinCEN will extend the relief to those areas automatically. 

To qualify for relief, the reporting company’s filing due date must fall between the following time periods: 

• For Beryl, a filing due date between July 4, 2024, and October 2, 2024, 
• For Debby, a filing due date between July 31, 2024, and October 29, 2024, 
• For Francine, a filing due date between September 8, 2024, and December 7, 2024,  
• For Helene, a filing due date between September 22, 2024, and December 21, 2024, and  
• For Milton, a filing due date between October 4, 2024, and January 2, 2025. 

The relief extends the filing deadline six months from the date the report would have been due. For instance, a reporting company formed in 2024 that is required to file a report on September 10, 2024, will now have until March 10, 2025, to file the initial report.  A reporting company formed before December 31, 2023, with an initial report due before January 1, 2025, will have until June 30, 2025, to file an initial report. 

This only applies to reporting companies whose principal place of business is within the designated disaster areas. The relief does not apply merely because beneficial owners reside in the impacted areas. However, FinCEN has advised that it will work with reporting companies whose principal place of business is outside the disaster area but who must consult records that are within those areas to help them meet their deadlines.  

This may impact reporting companies in the following states: 

• Alabama 
• Florida 
• Georgia 
• Louisiana 
• Pennsylvania 
• North Carolina 
• South Carolina 
• Tennessee 
• Texas 
• Vermont 
• Virginia 

Reporting companies impacted by these hurricanes should reach out to legal counsel to determine their reporting obligations and evaluate if they qualify for this relief.