Below is a summary of the latest developments surrounding the CTA and the steps required for compliance:

As you may know, On December 3, 2024, U.S. District Judge Amos Mazzant in Texas issued a nationwide preliminary injunction, temporarily halting the enforcement of the CTA. This injunction was granted on the grounds that the plaintiffs demonstrated a significant likelihood of success in their claim that the CTA violates the Tenth Amendment by infringing upon states' rights (Reuters). Following the decision, the U.S. Department of Justice filed an appeal on December 5, 2024, indicating its intent to challenge the court's decision.

On December 17, 2024, The National Small Business Association (NSBA) successfully secured a one-year delay in the implementation of the CTA’s Beneficial Ownership Information (BOI) reporting requirements. This postponement was achieved through a provision in a Continuing Resolution spending bill signed into law that day, funding the government through March 14, 2025.

On December 23, 2024, the Fifth Circuit Court of Appeals reversed the District Court's nationwide preliminary injunction. This decision reinstates the requirement to file Beneficial Ownership Information (B)I) reports. Businesses would have until January 13, 2025, to complete their filings.

On December 26, 2024, the Fifth Circuit Court of Appeals vacated its earlier decision, reinstating the nationwide injunction. This decision effectively halts the enforcement of the CTA until further notice. 

Finally, on December 27, 2024, FinCEN announced that businesses are no longer required to file BOI reports at this time. While voluntary filings may still be submitted, mandatory compliance is suspended pending further guidance

Because the BOI reporting requirement seems to be changing, almost weekly, due to court challenges, WSMTA suggests that you sign up for alerts directly from FinCEN. Click the link below to see recent Alerts as well as sign up to receive alerts.

https://fincen.gov/boi

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