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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

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.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.
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