On Tuesday, December 3, 2024, a federal district court in Texas issued an order granting a nationwide preliminary injunction that blocks the Corporate Transparency Act (CTA)’s beneficial ownership information (BOI) reporting requirements, and the related deadlines to comply with the CTA’s reporting requirements, including the initial filing deadline for companies established prior to 2025 that have a January 1, 2025 deadline.

The Department of Justice, on behalf of the Department of the Treasury, filed an appeal of the district court’s decision on December 5, 2024. The potential outcome of BOI reporting, including when reports need to be submitted, remains unknown.

The Financial Crimes Enforcement Network (FinCEN) has responded that as long as the preliminary injunction remains in effect reporting companies are not required to report BOI to FinCEN and reporting companies will not be subject to liability for failing to report their BOI. 

FinCEN also indicated that reporting companies may continue to voluntarily submit BOI reports.

We are actively monitoring this ongoing situation and the related implications as it pertains to the filing deadline and potential penalties.