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I Went to Bed and the Rules Changed: the Corporate Transparency Act is Back on Hold

Client Alert
December 27, 2024

Yesterday we told you that the Fifth Circuit had reinstated the Corporate Transparency Act’s filing requirements, overturning the prior injunction [read the article here].

Now the Court has reversed course, overturned its decision from 3 days ago, and reinstated the nationwide injunction.

The United States Court of Appeals for the Fifth Circuit ordered on December 26, 2024 that in an effort to “preserve the constitutional status quo” while it considered the Federal Government’s appeal, it vacated the prior order for a stay of the nationwide injunction pending appeal entered on December 23, 2024, and reinstated the preliminary injunction enjoining enforcement of the CTA and its corresponding Reporting Rule.

What to do now?

As of this morning, the FinCEN website had not been updated to reflect the December 26, 2024 order. With all of the back-and-forth orders and updates, a measure of caution should be applied: proceed as-if the law could change in a matter of days. That is, if you have not complied with the CTA and its corresponding Reporting Rule, have all of your information ready in case the preliminary injunction is lifted again.

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 and corporate lawBeneficial Ownership Information Reporting
Client Alert

FTC Continues to Target Noncompetes

September 11, 2025The FTC is intensifying its focus on noncompete agreements in healthcare, urging employers to review contracts for compliance. While Ohio still generally enforces noncompetes, pending legislation could limit their use.Client Alert

Medicare Updates: Prior Authorizations and Physician Fee Schedule

September 8, 2025The Centers for Medicare & Medicaid Services (CMS) has announced two key updates effective January 1, 2026: a six-state prior authorization pilot program targeting high-risk services under the WISeR Model, and proposed revisions to the Physician Fee Schedule (PFS) that include increased payment rates, expanded telehealth coverage, and updated policies for chronic care, behavioral health, and rural providers.Client Alert

USCIS Policy Updates: Implications for Business Immigration

August 20, 2025In August 2025, USCIS issued three key policy updates enhancing vetting, good moral character (GMC) evaluations, and scrutiny of "anti-American" conduct in immigration adjudications. These policy memos will impact employers sponsoring foreign workers, including H-1B, L-1, EB visas, adjustments, and naturalization.Client Alert

Ohio Passes Antidiscrimination Provision for CRNA Reimbursement

August 14, 2025Ohio has passed House Bill 96, introducing a provider nondiscrimination provision that requires health plans to reimburse certified registered nurse anesthetists (CRNAs) at the same rate as physicians for the same services. The law aims to improve patient access to care by eliminating payment discrimination against CRNAs and will take effect on September 30, 2025.Client Alert

Ohio Board of Pharmacy | Administrative Code Rule Changes

July 16, 2025The Ohio Board of Pharmacy (“BOP”) recently posted notices of Ohio Administrative Code rule changes related to record keeping and the sale and distribution of certain ephedrine-containing products.
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