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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

Permanent Injunction of “Heartbeat” Abortion Ban in Ohio

October 28, 2024Hamilton County Common Pleas Judge Christian Jenkins has ruled Ohio’s six-week abortion ban unconstitutional, citing the state’s new reproductive rights amendment. This ruling emphasizes that Ohio law must fully reflect the will of voters, offering clarity for medical providers and safeguarding women's health care rights.Multimedia, Client Alert

Trump vs. Harris: What Could Their Presidencies Mean for Employment Law?

October 22, 2024In the latest 2 episodes of Employment Law After Hours, BMD Partner Bryan Meeks dives deep into the potential employment law changes we could see under two very different 2024 election outcomes with Kamala Harris or Donald Trump.Client Alert

Charitable Planning: A Menu of Options

October 14, 2024Find out ways you can take advantage of charitable planning to minimize the amount of estate taxes due. Here are some of the popular charitable planning techniques, their uses, and some general advice regarding their formation.Multimedia, Client Alert

Nationwide Ban on Non-Compete Agreements: Requirements and Texas Court Decision Explained

September 4, 2024Watch this Employment Law After Hours video to find out about the Federal Trade Commission’s (FTC) groundbreaking Final Rule that bans non-compete agreements nationwide. This video also explores the recent decision by the Northern District of Texas to enjoin and delay the implementation and enforcement of the Final Rule banning non-compete agreements nationwide.Client Alert

Parental Approval Mandate for Diagnosing Gender-Related Conditions in Minors under Ohio House Bill 68

September 4, 2024Ohio House Bill 68, effective August 6, 2024, introduces strict guidelines for mental health professionals diagnosing and treating minors with gender-related conditions. The law mandates parental or guardian consent before any diagnosis or treatment can proceed. Additionally, professionals must first screen for other comorbidities and assess for any history of abuse. Failure to adhere to these requirements can result in disciplinary action for unprofessional conduct.
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