Treasury Department Finalizes Rule Eliminating Small Business Reporting Requirement
Treasury Department Finalizes Rule Eliminating Small Business Reporting Requirement
NLBMDA
The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) finalized its revised beneficial ownership information (BOI) reporting rule, locking in current exemptions for U.S. businesses and moving forward with the deletion of personal information previously collected from millions of American business owners.
The final rule, which took effect August 14, makes permanent at the regulatory level changes first announced by the White House in March 2025. Under the rule, U.S.-based companies are exempt from BOI reporting requirements under the Corporate Transparency Act (CTA). U.S. persons are also exempt from providing BOI to reporting companies, and U.S. individuals who previously obtained a FinCEN identifier are no longer required to update or correct their information.
Reporting requirements remain in place for certain entities formed under foreign law and registered to do business in the United States, although those entities are generally required to report information only on foreign beneficial owners.
FinCEN also confirmed that it will conduct a one-time sweep of its BOI database to remove “as much as practicable” information belonging to U.S. companies and U.S. persons that would not have been required under the revised rules. Businesses and individuals do not need to contact FinCEN or submit a request to have their information deleted. FinCEN plans to issue a public notice once the deletion process is complete.
FinCEN estimates that approximately 15 million reports from domestic businesses had already been submitted before the reporting requirements were narrowed in 2025. FinCEN estimates that the reporting exemptions first implemented in 2025 reduce annual compliance burdens by approximately 53 million hours and $9 billion compared with the original BOI reporting requirements.
NLBMDA Advocacy on BOI Reporting Requirements
The final rule represents the latest development in NLBMDA’s effort to address the CTA’s impact on LBM dealers. As implementation approached, NLBMDA continued pressing both Congress and the executive branch for relief. In January 2025, NLBMDA joined more than 60 trade associations in calling on the White House to provide a long-term delay while litigation surrounding the law continued, while also advocating for permanent legislative relief.
Following Treasury’s favorable decision to exempt domestic businesses, NLBMDA subsequently joined more than 100 trade associations urging the Department to finalize those protections and remove previously collected BOI belonging to U.S. businesses.
NLBMDA has also supported H.R. 425, the Repealing Big Brother Overreach Act, which would codify the foreign-focused reporting framework in federal law and require the deletion of BOI previously collected from U.S.-based companies.
During House Financial Services Committee consideration of the bill earlier this year, Rep. Warren Davidson (R-OH) specifically recognized NLBMDA’s support and submitted NLBMDA’s letter into the congressional record.
Work Remains in Congress
While the final rule provides significant regulatory certainty, the underlying Corporate Transparency Act remains federal law. A future administration could seek to revisit FinCEN’s regulatory exemptions, making congressional action important for providing lasting certainty to small businesses.
H.R. 425 was approved by the House Financial Services Committee in April by a 26-25 vote. As reported, the legislation would largely codify FinCEN’s current foreign-focused reporting approach and require the deletion of BOI previously collected from Americans. The legislation has been reported to the House and is currently awaiting consideration by the full chamber.
Questions? Please contact NLBMDA Government Affairs Coordinator Matthew Delaney at mdelaney@dealer.org.
Following Treasury’s favorable decision to exempt domestic businesses, NLBMDA subsequently joined more than 100 trade associations urging the Department to finalize those protections and remove previously collected BOI belonging to U.S. businesses.
NLBMDA has also supported H.R. 425, the Repealing Big Brother Overreach Act, which would codify the foreign-focused reporting framework in federal law and require the deletion of BOI previously collected from U.S.-based companies.
During House Financial Services Committee consideration of the bill earlier this year, Rep. Warren Davidson (R-OH) specifically recognized NLBMDA’s support and submitted NLBMDA’s letter into the congressional record.
Work Remains in Congress
While the final rule provides significant regulatory certainty, the underlying Corporate Transparency Act remains federal law. A future administration could seek to revisit FinCEN’s regulatory exemptions, making congressional action important for providing lasting certainty to small businesses.
H.R. 425 was approved by the House Financial Services Committee in April by a 26-25 vote. As reported, the legislation would largely codify FinCEN’s current foreign-focused reporting approach and require the deletion of BOI previously collected from Americans. The legislation has been reported to the House and is currently awaiting consideration by the full chamber.
Questions? Please contact NLBMDA Government Affairs Coordinator Matthew Delaney at mdelaney@dealer.org.