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Corporate Transparency Act Effective Again

Client Alert
February 20, 2025

Over the past several months, the federal judiciary has provided numerous rulings on the enforceability of the Corporate Transparency Act (CTA), which became effective January 1, 2024. For a more detailed overview on the CTA, click here.

On January 24th, we alerted business owners that enforcement of the CTA was barred nationwide pursuant to federal litigation in Texas (Smith v. U.S. Department of the Treasury, Case No. 6:24-cv-336-JDK). However, on February 18th, the Court in Smith lifted its previous stay which prevented enforcement of the CTA.

Due to this updated ruling, the CTA’s reporting requirements are back in effect nationwide. Non-exempt entities now have until March 21, 2025 to submit required reporting. 

Entities that have not completed reporting should re-engage compliance efforts immediately to meet this updated deadline. The civil penalty for failing to file reporting required under the CTA is $591 per day, up to a total of $10,000. Note also that criminal penalties are authorized for any person who willfully (i) provides or attempts to provide false/fraudulent information, or (ii) fails to report and/or update a report previously made.

For guidance on complying with these updated requirements, business owners should reach out to their BMD legal advisors or contact BMD Member Blake Gerney at brgerney@bmdllc.com.

Corporate Transparency ActBusiness & Corporate LawBlake R. GerneyMichael SneeringerNathan AltstadtJacob R. Davis
Client Alert

New $100,000 Fee on H-1B Petitions – Legal Immigration

September 23, 2025President Trump issued an Executive Order (EO) imposing a $100,000 payment to accompany any new H-1B visa petitions submitted after 12:01 a.m. eastern time on September 21, 2025 and will remain in place for 12 months (unless extended).Client Alert

Implications of Supreme Court Stay for Business Operations in Noem v. Vasquez Perdomo

September 16, 2025On September 8, 2025, the U.S. Supreme Court temporarily reinstated immigration officers’ authority to conduct brief stops based on factors such as location, work type, language, or appearance. This stay in Noem v. Vasquez Perdomo allows enforcement actions to resume in California pending appeal. Employers in industries like construction, agriculture, landscaping, and day labor should prepare for increased worksite disruptions and review compliance protocols.Client Alert

Ohio House Bill 429: Potential Relief for Providers Facing Same-Day Reimbursement Restrictions

September 15, 2025Ohio House Bill 429 aims to prevent third-party payers from reducing provider reimbursement for multiple procedures performed on the same day. The bill could improve payment practices for a range of specialties, including surgery and gastroenterology.Client Alert

FTC Continues to Target Noncompetes

September 11, 2025The FTC is intensifying its focus on noncompete agreements in healthcare, urging employers to review contracts for compliance. While Ohio still generally enforces noncompetes, pending legislation could limit their use.Client Alert

Medicare Updates: Prior Authorizations and Physician Fee Schedule

September 8, 2025The Centers for Medicare & Medicaid Services (CMS) has announced two key updates effective January 1, 2026: a six-state prior authorization pilot program targeting high-risk services under the WISeR Model, and proposed revisions to the Physician Fee Schedule (PFS) that include increased payment rates, expanded telehealth coverage, and updated policies for chronic care, behavioral health, and rural providers.
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