GSCPA Joins AICPA in Letter to Voice Concerns with BOI Rollout and Request Delay of Enforcement

The Georgia Society of CPAs, along with the AICPA, recently called on the U.S. Department of the Treasury and the Financial Crimes Enforcement Network (FinCEN) and voiced serious concerns regarding the enforcement of the Beneficial Ownership Information (BOI) reporting requirements.

Letter Summary 
The letter – signed by all 54 state CPA societies and the AICPA – asks that all enforcement actions be suspended until one year after the conclusion of all court cases related to National Small Business Association (NSBA) v. Yellen and believes that no retroactive enforcement for non-compliance should happen during this time. In addition to the estimated burden hours and associated time cost, the letter also urged caution regarding failing to provide a reasonable timeframe for small businesses to comply with BOI for both new and existing entities, which has effectively become a 30-day tracking requirement. 

The letter raises an alarm because of a March 1st court ruling that finds that the Corporate Transparency Act (CTA) is unconstitutional. This ruling only applies to NSBA members as of March 1, meaning those NSBA members currently do not need to file a BOI report, but the filing requirement stands for all other businesses. 

Furthermore, the letter asks that no small business should be compelled to file or face enforcement for failure to comply until after the courts have worked through this complex case. BOI reporting requirements went into effect on January 1, 2024. 

The Georgia Society of CPAs has serious concerns with the BOI reporting requirement small businesses are being required to submit to the Financial Crimes Enforcement Network (FinCEN), beginning this year for new entities. This reporting requirement is expected to heavily impact small firm CPA practitioners in our state and their small business clients.  Across the country, small businesses are not universally aware of the rule. GSCPA believes that many are and will be unprepared to meet their reporting obligation and face significant consequences including civil and criminal penalties should they fail to report. 

Stay Informed 
The Georgia Society of CPAs will continue these efforts to delay the implementation of BOI and allow for additional time for small businesses and their CPA business advisors to understand the potential impact of these reporting requirements, including steep penalties for non-compliance. GSCPA will continue to actively participate in the process. We’re working for you!

To read the letter signed by all 54 state CPA Societies and the AICPA, click here. 

For more on legislation and representation or to locate your local representatives, visit If you have any questions on this issue, contact Don Cook, vice president, legislative affairs at 404-877-2154 (mobile) or