The bodies are asking the Department of the Treasury and the Financial Crimes Enforcement Network to suspend enforcement actions until one year after the conclusion of all court cases related to NSBA vs. Yellen. They also want no retroactive enforcement actions for non-compliance during this time period. 

The AICPA has written to FinCen and the United States Congress expressing concern about what it calls a “constricted timeline” for the small business community to understand the reporting requirement. The AICPA said there is not a reasonable period for SMBs to comply with BOI for new and existing entities.

The AICPA also cited concerns over estimated burden hours associated time-cost which it says has effectively become a 30-day tracking requirement.

Besides outlining its concerns several times, the letter said the AICPA will “continue to ask for a legislative delay should FinCEN continue enforcement activities while confusion remains within the small business community and for those financial professionals working to support their small business clients.”