Corporate Transparency Act—Don’t file if...

Happy Sunday morning!

Before the week kicks off, two things for you:

1. Corporate Transparency Act UPDATE: Things have changed AGAIN—DO NOT file a Beneficial Ownership Information report for your LLC or corporation if…

2. Dear TCoL: I’m way behind on all my employee reviews. How do I get back on track?

Let’s set you up for a strong week—after a well-earned Sunday recharge.

-TCoL

Missed our last feature article? “Why Smart Founders Rarely Split Equity Evenly”

Read it here.

UPDATE: Corporate Transparency Act—Don’t file if…

The communication around the Corporate Transparency Act’s Beneficial Ownership (BOI) reporting has been a mess. If you own an LLC or corporation, you've likely been left wondering whether you need to file. And even today, if you check FinCEN’s website (here), you’ll still see the 21 March 2025 deadline.

But here’s the latest—straight from a 2 March 2025 U.S. Treasury press release that you won’t find on the FinCEN website:

March 2, 2025

The Treasury Department is announcing today that, with respect to the Corporate Transparency Act, not only will it not enforce any penalties or fines associated with the beneficial ownership information reporting rule under the existing regulatory deadlines, but it will further not enforce any penalties or fines against U.S. citizens or domestic reporting companies or their beneficial owners after the forthcoming rule changes take effect either. The Treasury Department will further be issuing a proposed rulemaking that will narrow the scope of the rule to foreign reporting companies only. Treasury takes this step in the interest of supporting hard-working American taxpayers and small businesses and ensuring that the rule is appropriately tailored to advance the public interest.

"This is a victory for common sense,” said U.S. Secretary of the Treasury Scott Bessent. “Today’s action is part of President Trump’s bold agenda to unleash American prosperity by reining in burdensome regulations, in particular for small businesses that are the backbone of the American economy.” ###

Here is the link to the full press release. It’s baffling that this isn’t posted on FinCEN’s website.

Bottom Line: DON’T FILE

FinCEN will accept your BOI report today, but don’t take the bait. Many people suspect they’re collecting as many “voluntary” reports as possible before the 21 March 2025 rule release shuts down collection efforts.

What If You Already Filed a BOI?

As of 15 March 2025:

• No Automatic Retraction – The Treasury’s announcement doesn’t void previously filed BOI reports.

• No Clear Retraction Process – FinCEN hasn’t provided a way to withdraw a filed report. Their correction process isn’t built for full retraction.

• Wait for Further Guidance – The interim final rule (expected 21 March 2025) may address this. No penalties for domestic filers means urgency is low, but your sensitive information is still on file.

• Contact FinCEN – You can reach out for clarification but expect slow or vague responses given the shifting rules.

Our Recommendation If You Already Filed and Want Your Information Removed:

1. Try contacting FinCEN – if you don’t mind sharing, we would love to hear what response you get. Let us know at [email protected].

2. Stay updated – follow us on X (@thecoletter) or LinkedIn (here). We’ll keep you informed as we have over the past few weeks.

Hopefully, the upcoming 21 March 2025 rule changes will include a clear retraction process. Until then, don’t file, and stay tuned.

Dear TCoL: Late Employee Reviews are “Disrespectful”

Question: I’m way behind on employee reviews to the point that I realize I need to get organized about it or have some system. Part of me doesn’t want to do them because I know reviews lead to conversations about raises. How do I get going again?

Answer: Procrastinating on employee reviews is like skipping dentist appointments—eventually, it catches up with you, and it’s rarely pleasant. But the solution is simple: start now.

Since it sounds like you’ve done reviews before, the first step is to put them on your calendar (and your employee’s). Don’t just pick one employee and hyper-focus on that person—you’ll overanalyze, and they’ll feel scrutinized. Schedule them all and give yourself enough time to prepare.

Andy Grove, the legendary Intel CEO, called late reviews “disrespectful.” Employees deserve regular feedback (and the raise discussion, if warranted).

So, your new system is straightforward:

1. Knock out the overdue reviews.

2. Immediately schedule the next cycle (annually, semi-annually—your call) and send invites.

That’s it. No expensive HR tracking software required—just calendar invites and discipline.

If you’re rusty, visit Andy Grove’s book, High Output Management. His section on performance reviews is a masterclass, full of practical advice. If you don’t have time to read it, grab the audiobook on Audible.

Either way, get moving. Delays won’t make the conversations any easier.

Have an interesting business question and need a free bit of advice? Send your question to [email protected]. No confidential info, please!