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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

Pre and Postnuptial Agreements | Necessary, Maybe, What Happened to Forever?

November 7, 2025Both Florida and Ohio now allow clients to enter into a prenuptial or postnuptial agreement prior to marriage or after marriage (Ohio previously did not allow postnuptial agreements). Both documents have statutory guidelines that must be followed in terms of execution and financial disclosure.Client Alert

DHS Ends All Employment Authorization Auto-Extensions

October 29, 2025Effective October 30, 2025, DHS ends all automatic work authorization renewals. The 540-day extension applies only to renewals filed before this date, and there is no grace period for expired EADs filed on or after October 30. Employers must audit EADs, train staff, ensure I-9 compliance, and plan for work authorization gaps. Penalties for noncompliance can be severe.Client Alert

CMS’s Rural Health Funding Announcement

October 27, 2025CMS has announced a $50 billion Rural Health Transformation (RHT) Program to improve healthcare access, quality, and outcomes in rural communities. All states are eligible to apply for funding by November 5, 2025. Half of the funds will be distributed equally, with the remainder based on state-specific factors. The program supports evidence-based initiatives, workforce recruitment, and access to treatment services, with awards assessed annuallyClient Alert

Expanding Access to Care: Ohio’s Effort to Modernize APRN Practice Through Ohio SB 258 and HB 508

October 24, 2025Ohio is moving to expand access to healthcare through Senate Bill 258 and House Bill 508, which would modernize APRN practice by removing the outdated requirement for a physician contract. This change would allow nurse practitioners, nurse midwives, and clinical nurse specialists to provide care more efficiently, especially in underserved areas, while maintaining high-quality, cost-effective care.Client Alert

Cleveland Joins the Pay Transparency Movement: What Employers Need to Know

October 21, 2025Beginning October 27, 2025, all Cleveland employers with 15 or more employees will be prohibited from asking applicants about their pay history and will be required to include reasonable pay ranges in all job postings where the position will be performed, solicited, considered, or processed in Cleveland. The ordinance is intended to help close the gender wage gap and promote greater pay equity across the city.
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