It’s been quite a roller coaster ride monitoring the ongoing litigation concerning the Corporate Transparency Act (“CTA”).  As of today, December 30, 2024, the CTA compliance requirement has been halted again, which means you presently do not need to comply with the CTA’s requirement for reporting your association’s beneficial ownership information.

Briefly, on December 3, 2024, the US District Court for the Eastern District of Texas published a decision in Texas Top Cop Shop, Inc., et al v. Garland, et al issuing a preliminary nationwide injunction against the CTA.  On December 23, a panel of the Fifth Circuit Court of Appeals lifted the injunction, thereby reinstating the January 1, 2025 compliance deadline.  The Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) then extended the filing deadline for most affected corporations to January 13, 2025.

On December 26, 2024, a different panel of the Fifth Circuit vacated the December 23 decision, which means the injunction is back in place today.  FinCEN has since updated its website (https://www.fincen.gov/boi) to reflect that the injunction is in effect again.  The FinCEN website now states:

“In light of a recent federal court order, reporting companies are not currently required to file beneficial ownership information with FinCEN and are not subject to liability if they fail to do so while the order remains in force. However, reporting companies may continue to voluntarily submit beneficial ownership information reports.”

The bottom line is that as of today, you do not need to worry about CTA compliance right now.  We will keep you informed if and when this changes again.