CTA – Where Does It Stand Today?

The Corporate Transparency Act (the "CTA" or the "Act") has dropped off of most people's radar, perhaps prematurely. Although December 2025 was not the CTA roller coaster that December 2024 was,¹ it still provided some year-end entertainment.

You may remember that the Financial Crimes Enforcement Network, an arm of the U.S. Department of the Treasury ("FinCEN"), issued the Interim Final Rule (the "Interim Rule") on March 21, 2025,² essentially eliminating the CTA's reporting requirements for U.S. entities and U.S. control persons. This removed the compliance concerns for probably 99% of our clients; only non-U.S. foreign entities qualified to do business in a state still have reporting requirements, and only with respect to their owners who are not "U.S. Persons" under the Act (as determined under the Interim Rule). FinCEN has estimated that the reporting requirements have gone from covering 36.5 million entities nationwide to affecting less than