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Corporate Transparency Act Overhauled: U.S. Entities No Longer Required to Report

Client Alert
March 24, 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 February 28th, we alerted business owners that they no longer had an obligation to submit reporting per updated guidance from the Department of Treasury. At the time, the Department of Treasury provided that the CTA would be re-evaluated in the coming weeks.

On March 21st, as promised, the Department of Treasury issued an interim final rule that significantly re-works the CTA. Going forward, all entities created in the United States and their beneficial owners will be exempt from the CTA’s reporting requirements. 

The only entities that are still required to submit beneficial ownership reporting are non-U.S. entities (entities formed under the laws of a foreign country) that are registered to do business in any U.S. state or tribal jurisdiction. Importantly, though, these non-U.S. entities are not required to submit beneficial ownership information for any of their owners that are U.S. citizens.

For further guidance on the changing landscape of CTA reporting, business owners should reach out to their BMD legal advisors or contact BMD Member Blake Gerney at brgerney@bmdllc.com.

Corporate Transparency ActBeneficial Ownership Information ReportingDepartment of TreasuryCTABlake R. GerneyJacob R. DavisBusiness & Corporate Law
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.Client Alert

CMS and Ohio Ramp Up Fraud Enforcement in Home Health and Hospice

May 15, 2026CMS and Ohio have launched sweeping new fraud prevention initiatives targeting home health and hospice providers, signaling a period of heightened scrutiny for enrollment, billing, documentation, and EVV compliance. While aimed at combating fraud, these measures also create significant operational and due process risks for compliant agencies, making proactive compliance programs, auditing, and governance more important than ever.Client Alert

MYTH BUSTER: Can a New Chiropractor Bill Under An Established Chiropractor’s NPI?

May 14, 2026Many chiropractic practices mistakenly believe a newly hired chiropractor can bill under an established chiropractor’s NPI while waiting for credentialing approval. In most cases, this is not permitted. Claims should be submitted under the NPI of the chiropractor who actually rendered the service to avoid compliance risks, including potential False Claims Act exposure. This article outlines key billing rules, common exceptions, and practical compliance tips for chiropractic practices.Client Alert

RNs and APRNs Take Note: Ohio Board of Nursing Mandates a New CE Reporting Period

April 29, 2026Ohio’s Board of Nursing has updated the continuing education reporting period for RNs and APRNs. Beginning March 26, 2026, CE credits must be completed between July 1 and June 30 of odd-numbered years, replacing the previous November to October timeframe.
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