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Corporate Transparency Act Reporting Deadline: December 31

Client Alert
November 4, 2024

The Corporate Transparency Act (“CTA”), which became effective January 1, 2024, imposes strict reporting guidelines on small business owners throughout the country. The deadline for non-exempt businesses to submit reporting is December 31, 2024.

The civil penalty for failing to file reporting required under the CTA if $591 per day, up to a total of $10,000. Also note that criminal penalties are authorized for any person who willfully (i) provides or attempts to provide false/fraudulent information or (ii) fails to report and/or update a report previously made.

If you are the beneficial owner of an entity formed pursuant to a filing with a state secretary of state’s office (i.e., an LLC or a corporation), your entity must report. There are a few exemptions to this reporting requirement. If an entity meets an exemption, it does not need to presently report.  However, if an exemption ever becomes inapplicable to the entity, the entity then has 30 days to report. 

Completed reports are not public record; reporting is maintained by the financial crimes wing of the Department of the Treasury in a database that’s only accessible by state and federal law enforcement.

To avoid facing a potential steep fine to kick of your 2025 fiscal year, or to better understand whether your entity needs to report, please do not hesitate to contact BMD Attorney Jacob R. Davis (jrdavis@bmdllc.com).

For a more detailed overview on the CTA, click here.

Corporate Transparency Act
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.Client Alert

Ohio Med Spas: Peptide Do's and Do Not's

April 29, 2026Recent guidance from the Ohio Board of Pharmacy outlines key compliance requirements for med spas using peptides. While some peptide drugs are FDA approved, others are not or cannot be compounded. Med spa operators should ensure they source medications from licensed suppliers, avoid non-approved or “research use only” products, and follow all compounding and storage regulations to maintain compliance and avoid enforcement actions.Client Alert

Substance Use Disorder Providers: 42 CFR Part 2 Now Enforceable

April 15, 2026Updates to 42 CFR Part 2 are now enforceable, bringing significant changes to how substance use disorder (SUD) records are handled. The Final Rule aligns Part 2 more closely with HIPAA, introduces updated penalties, allows a single patient consent for treatment, payment, and operations, and adds new requirements for Notices of Privacy Practices. It also creates a formal definition of SUD counseling notes and imposes strict consent requirements for their use and disclosure. Providers should review and update policies to ensure compliance.Client Alert

AAA Introduces AI-Assisted Arbitrator for Certain Disputes

April 7, 2026The American Arbitration Association has introduced an AI-assisted arbitration platform designed to streamline certain document-based disputes. While a human arbitrator still makes the final decision, the technology can improve efficiency, reduce costs, and accelerate case resolution. Companies should weigh these benefits against considerations such as transparency, risk, and contractual requirements before adopting AI-assisted arbitration.Client Alert

Quiet Hours Texts and TCPA Claims: Consent Remains King as Courts Divide on Text Messages

March 31, 2026Businesses face increasing TCPA lawsuits over off-hours marketing texts, but recent court decisions highlight strong defenses. Clear consumer consent and updated terms and conditions can defeat many claims, while a growing number of courts are finding that text messages are not “telephone calls” under the statute. Proactive compliance measures, including clickwrap agreements and forum-selection clauses, are critical to reducing risk.
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