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Corporate Transparency Act Is Back in Effect: Are You Ready?

Client Alert
December 26, 2024

On December 5, 2024, the Federal Government was enjoined from enforcing the Corporate Transparency Act (CTA) in Texas Top Cop Shop, Inc., et al v. Garland et al, No. 4:2024 cv 00478 - Document 30 (E.D. Tex. 2024). At least for now, that prior ruling has been overturned and the filing requirements under the CTA are back in effect. 

On December 23, 2024, the United States Court of Appeals for the Fifth Circuit granted the Federal Government’s emergency motion for a stay of the nationwide injunction pending appeal. According to the Fifth Circuit, the Federal Government “met its burden” for it to issue a stay and reinstate the obligations under the CTA.

In addition to the widely circulated court opinion, the Financial Crimes Enforcement Network (FinCEN) website gives businesses the following guidelines:

  • First, reporting companies that were created or registered prior to January 1, 2024, now have until January 13, 2025, to file their initial beneficial ownership information reports with FinCEN (it was previously January 1, 2025).
  • Second, reporting companies created or registered on or after September 4, 2024, that had a filing deadline between December 3, 2024, and December 23, 2024, have until January 13, 2025, to file their initial beneficial ownership information reports with FinCEN (it was previously 30 days from creation or registration).
  • Third, reporting companies created or registered on or after December 3, 2024, and on or before December 23, 2024, have an additional 21 days from their original filing deadline to file their initial beneficial ownership information reports with FinCEN (it was previously 90 days from creation or registration).

What to do now?
Based on the Court ruling and update to the FinCEN website, reporting companies are required to comply with the law and file beneficial ownership reports as provided in FinCEN’s regulations, albeit with the updated deadlines described above.

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 LawBeneficial Ownership Information Reporting
Client Alert

Florida Super Lawyers® Recognizes Brennan Manna Diamond Attorneys to the 2026 Lists

June 26, 2026BRENNAN, MANNA & DIAMOND is proud to announce that three of our attorneys have been designated to the 2026 Florida Super Lawyers® and Florida Rising Stars® lists. Super Lawyers is based on multiple categories of independent research and peer evaluation to identify outstanding lawyers.Client Alert

Supreme Court Clears Path for TPS Terminations: What Employers Need to Know

June 25, 2026The U.S. Supreme Court's June 25, 2026 decision in Mullin v. Doe and Trump v. Miot removed legal obstacles that had delayed the termination of Temporary Protected Status (TPS) for Haiti and Syria. The ruling also reinforces the administration's authority to terminate other TPS designations currently under review. Employers should immediately identify workers whose employment authorization is tied to affected TPS programs, review Form I-9 records, and prepare for forthcoming USCIS guidance before taking any employment action.Client Alert

The Risks of Outsourcing Medical Billing and the Importance of State-Law Compliance

June 24, 2026Offshoring medical billing and other administrative functions can reduce costs, but it also raises significant compliance, operational, and contractual risks. Although HIPAA does not explicitly prohibit protected health information from being accessed or stored outside the United States, healthcare providers and their vendors remain responsible for safeguarding patient information and complying with state-specific restrictions that may limit or prohibit offshore subcontracting.Client Alert

Risks of Using AI-Generated, Implied Celebrity Endorsements in Advertising

June 3, 2026Businesses using AI-generated celebrity images, videos, or voice simulations in advertising may face significant legal risks if the content falsely implies an endorsement, affiliation, or sponsorship. This article discusses potential exposure under false advertising, right of publicity, consumer protection, and professional conduct laws, and explains why disclaimers may not be enough to avoid liability.Client Alert

CMS Requires Providers to Use an Updated Advance Beneficiary Notice (ABN) Form by May 12, 2026

May 22, 2026CMS has released an updated Advance Beneficiary Notice of Noncoverage (ABN), Form CMS-R-131, that all providers and suppliers must begin using by May 12, 2026. The revised form includes clearer language and formatting updates intended to improve patient understanding and compliance.
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