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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

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.Client Alert

USCIS Policy Updates: Implications for Business Immigration

August 20, 2025In August 2025, USCIS issued three key policy updates enhancing vetting, good moral character (GMC) evaluations, and scrutiny of "anti-American" conduct in immigration adjudications. These policy memos will impact employers sponsoring foreign workers, including H-1B, L-1, EB visas, adjustments, and naturalization.
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