Reminder Federal: Corporate Transparency Act (CTA) Still Dead

We wanted to remind businesses that the Corporate Transparency Act (CTA) and all its requirements are still suspended. FinCEN had not yet commented on the December 26, 2024, order.

A development timeline of what has happened can be seen below:

• 2021: Congress enacted the Corporate Transparency Act, establishing a reporting deadline of January 1, 2025.
• December 3, 2024: A federal court in Texas issued an injunction, pausing the CTA’s reporting requirements.
• December 23, 2024: The 5th Circuit’s motions panel overturned the injunction, reinstating the CTA. Consequently, the government extended the reporting deadline to January 13, 2025.
• December 26, 2024: Another panel from the 5th Circuit reinstated the nationwide injunction to maintain the status quo during an expedited appeal review.
• Upcoming: The 5th Circuit is scheduled to hear arguments on March 25, 2025, with briefing schedules set for February.

The injunction does not stop companies from submitting Beneficial Ownership Information (BOI)   reports, and the FinCEN website remains open for filings. While not currently mandatory, businesses may choose to comply with the regulations, including initial reports for entities formed before January 1, 2024, to reduce ongoing uncertainty.

Vensure will monitor the development and inform the business of any updates.

For additional information:

• Federal: Texas Court Suspends (for Now) the Enforcement of the Corporate Transparency Act (CTA) (VensureHR)
• Corporate Transparency Act Update (VensureHR)

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