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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

Top Compliance Risks for Ohio Med-Spas in 2025

November 11, 2025The Ohio Board of Pharmacy has increased inspections of med-spas holding Terminal Distributor of Dangerous Drugs (TDDD) licenses, with many facing enforcement actions in 2025. Common issues include purchasing from unlicensed distributors, improper drug storage, inadequate recordkeeping, and insufficient prescriber oversight. Understanding these risks and maintaining compliance can help protect your practice from penalties and license suspension.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.
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