Corporate Transparency Act Compliance Once Again Temporarily Suspended Nationwide
December 27, 2024
By: William P. Matthews and Sarah Buchanan
Once again, reporting companies are temporarily relieved from complying with the Corporate Transparency Act’s (“CTA”) requirement to report beneficial ownership information (“BOI”) to the Financial Crimes Enforcement Network (“FinCEN”).
On Dec. 26, 2024, a different panel of the United States Court of Appeals for the Fifth Circuit, in Texas Top Cop Shop, Inc. v. Merrick Garland, Attorney General of the United States (Case No. 4:24-cv-478, E.D. Tex.), vacated the part of the court’s Dec. 23 order that had reinstated CTA filing obligations and for which FinCEN subsequently established an extended deadline of Jan. 13, 2025.
As a result, the nationwide temporary injunction previously granted by the U.S. District Court for the Eastern District of Texas has been reinstated, and reporting companies are not currently required to comply with the CTA’s reporting obligations or deadlines. This temporary injunction will remain in place while the Court prepares to hear expedited oral arguments on the merits of the case.
While the CTA’s future continues to face legal uncertainty, the rapid developments of recent weeks emphasize the importance for reporting companies to be prepared to file their BOI reports on short notice.
For More Information
If you have questions or want more information regarding the nationwide temporary injunction and its possible effects on your business entity, contact your legal counsel. If you do not have regular counsel for such matters, Foulston Siefkin LLP would welcome the opportunity to work with you to meet your specific needs. For more information, contact Bill Matthews at 316.291.9556 or bmatthews@foulston.com. For more information on the firm, please visit our website at www.foulston.com.
Established in 1919, Foulston Siefkin is the largest Kansas-based law firm. With offices in Wichita, Kansas City, and Topeka, Foulston provides a full range of legal services to clients in the areas of administrative & regulatory; antitrust & trade regulation; appellate law; banking & financial services; business & corporate; construction; creditors’ rights & bankruptcy; e-commerce; education & public entity; elder law; employee benefits & ERISA; employment & labor; energy; environmental; ERISA litigation; estate planning & probate; family business enterprise; franchise & distribution; government investigations & white collar defense; governmental liability; government relations & public policy; healthcare; immigration; insurance regulatory; intellectual property; litigation & disputes; long-term care; mediation/dispute resolution; mergers & acquisitions; Native American law; noncompete & trade secret litigation; oil, gas & minerals; OSHA; privacy & data security; private equity & venture capital; product liability; professional malpractice; real estate; renewable energy, storage, and transmission; securities & corporate finance; startup/entrepreneurship; supply chain management; tax-exempt organizations; taxation; and water rights.
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This update has been prepared by Foulston Siefkin LLP for informational purposes only. It is not a legal opinion; it does not provide legal advice for any purpose; and it neither creates nor constitutes evidence of an attorney-client relationship.
