Skip to Content
As previously reported, enforcement of the Corporate Transparency Act (“CTA”) had been temporarily halted due to several legal challenges. Notably, the U.S. District Court for the Eastern District of Texas, in Texas Top Cop Shop, Inc. v. Garland issued an order on December 3, 2024, and in Smith, et al. v. U.S. Department of the Treasury, et al., issued an order on January 7, 2025, in each instance staying the implementation of the CTA’s reporting requirements.
However, recent legal developments have altered this status. On January 23, 2025, the U.S. Supreme Court lifted the nationwide injunction that had been granted in Texas Top Cop Shop, Inc. v. Garland. Subsequently, on February 17, 2025, the Texas district court granted the government’s motion to stay its previous order in Smith, et al. v. U.S. Department of the Treasury, et al, effectively lifting the nationwide injunction that had prevented enforcement of the CTA. Consequently, the CTA’s beneficial ownership information (“BOI”) reporting requirements are back in effect.
In response to these developments, the Financial Crimes Enforcement Network (“FinCEN”) announced on February 19, 2025, that for most reporting companies, the new deadline to file initial, updated, or corrected BOI reports is March 21, 2025. However, companies previously granted extended deadlines due to being in designated disaster areas—such as those affected by Hurricanes Milton, Helene, Francine, Debby, or Beryl—should adhere to their specific extended deadlines. FinCEN has also indicated that it may further modify reporting deadlines or requirements, particularly for lower-risk entities, and plans to initiate a process this year to revise the BOI reporting rule to reduce burdens on such entities.
Further information on the CTA and its requirements can be found in KWGD’s original alert at https://www.kwgd.com/news/the-corporate-transparency-act-2/.
Given the fluid nature of this situation, reporting companies should prepare to comply with the current March 21, 2025, deadline. Our firm is closely monitoring these developments and is ready to assist in navigating the reinstated reporting requirements. For questions on the CTA or how this decision may affect your organization, please contact KWGD.
Written by:
Attorneys Matthew R. Hull and Nathan C. Newcomer
Krugliak, Wilkins, Griffiths & Dougherty Co., L.P.A.
330-497-0700
mhull@kwgd.com, nnewcomer@kwgd.com