It’s truly the holiday season, with gifts being exchanged, returned, and even rescinded. In the spirit of surprises, the Fifth Circuit has decided to return one of its recent decisions regarding the Corporate Transparency Act (CTA).
Below is a brief timeline to help you stay informed:
Timeline of Decisions
- December 23, 2024: The Fifth Circuit motions panel reinstated CTA filing obligations, extending the compliance deadline to January 13, 2025.
- December 26, 2024: The Fifth Circuit merits panel vacated the stay on the preliminary injunction, once again pausing nationwide compliance requirements.
Key Impacts
- Compliance Paused: Reporting companies are not required to file beneficial ownership information with FinCEN.
- No Final Ruling: The preliminary injunction is still under review and further appeals or changes may arise in the coming weeks.
Guidance for Reporting Companies
- If You’ve Already Filed: You are fully compliant should CTA enforcement resume.
- If You Haven’t Filed: Filing is voluntary and can be done for free on FinCEN’s website.
What’s Next for the CTA?
We are monitoring this evolving situation and will continue to provide updates as developments unfold. In the meantime, we encourage members to review their potential CTA obligations and remain prepared for any changes in requirements. For more insights, please read the detailed update from Dykema here.
Thank you for your attention to this matter and your continued commitment to our shared mission.
