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Corporate Transparency Act to be Re-evaluated

Client Alert
February 28, 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 20th, we alerted business owners that the reporting required by the CTA was reinstated, as all nationwide federal injunctions had been lifted. However, on February 27th, the Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a press release providing that no enforcement actions will be taken against businesses that fail to submit reporting.

The press release provides that FinCEN will be reevaluating the CTA and will provide new guidance and clarity “as quickly as possible.”  Public comment will be solicited by FinCEN during this reevaluation.

Given FinCEN’s new position on the CTA, businesses no longer have any obligation to submit reporting.  A reevaluation of reporting obligations will also be warranted by business owners in the event FinCEN does publish a new final reporting rule, as the impetus for change was a reduction of the regulatory burden on businesses while prioritizing reporting only for those entities that pose the most significant risks.

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 ActBusiness & Corporate LawBlake R. GerneyMichael SneeringerNathan AltstadtJacob R. Davis
Client Alert

Update on Temporary Protected Status (TPS) for Haiti and Related Countries

July 13, 2026USCIS has temporarily extended Employment Authorization Documents (EADs) for certain Temporary Protected Status (TPS) beneficiaries from Haiti and several other countries following recent court action. Employers and TPS recipients should review EAD expiration dates, monitor ongoing developments, and ensure compliance with Form I-9 and E-Verify requirements.Client Alert

HHS Accessibility Requirements for Medical Diagnostic Equipment: What Health Care Providers Need to Know

July 8, 2026Health care providers that receive federal financial assistance are now subject to updated HHS accessibility requirements for medical diagnostic equipment under Section 504 of the Rehabilitation Act. With the July 8, 2026, compliance deadline in effect, covered providers should ensure they have the required accessible equipment, train staff, and review operational practices to reduce compliance risk and provide accessible care for patients with disabilities.Client Alert

Florida Super Lawyers® Recognizes Brennan Manna Diamond Attorneys to the 2026 Lists

June 26, 2026BRENNAN, MANNA & DIAMOND is proud to announce that three of our attorneys have been designated to the 2026 Florida Super Lawyers® and Florida Rising Stars® lists. Super Lawyers is based on multiple categories of independent research and peer evaluation to identify outstanding lawyers.Client Alert

Supreme Court Clears Path for TPS Terminations: What Employers Need to Know

June 25, 2026The U.S. Supreme Court's June 25, 2026 decision in Mullin v. Doe and Trump v. Miot removed legal obstacles that had delayed the termination of Temporary Protected Status (TPS) for Haiti and Syria. The ruling also reinforces the administration's authority to terminate other TPS designations currently under review. Employers should immediately identify workers whose employment authorization is tied to affected TPS programs, review Form I-9 records, and prepare for forthcoming USCIS guidance before taking any employment action.Client Alert

The Risks of Outsourcing Medical Billing and the Importance of State-Law Compliance

June 24, 2026Offshoring medical billing and other administrative functions can reduce costs, but it also raises significant compliance, operational, and contractual risks. Although HIPAA does not explicitly prohibit protected health information from being accessed or stored outside the United States, healthcare providers and their vendors remain responsible for safeguarding patient information and complying with state-specific restrictions that may limit or prohibit offshore subcontracting.
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