CTA Enforcement Halted Again by Fifth Circuit

On December 26, 2024, the U.S. Court of Appeals for the Fifth Circuit vacated its previous order, issued only a few days earlier on December 23, 2024, that reinstated the enforcement of the Corporate Transparency Act (CTA) and its beneficial ownership information (BOI) reporting requirements. This means that the nationwide preliminary injunction granted earlier this month by the U.S. District Court for the Eastern District of Texas is effectively back in place. Thus, the enforcement of the CTA and its BOI reporting requirements is once again halted and reporting companies are not required to meet FinCEN’s reporting deadlines at this time.

As a reminder, this injunction is a preliminary injunction, not a permanent one, and therefore not a final decision on the CTA and its BOI reporting requirements. We will continue to monitor developments and keep you informed of any changes.

If you have any questions about the CTA, please feel free to contact your trusted Rosenberg & Estis, P.C. attorney or William R. Byers, Member of the firm’s Transactional Department, who authored the above on the CTA.