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ARTICLE · 09 JANUARY 2025

Reversing Course, Fifth Circuit Halts CTA Reporting Requirements

Davis+Gilbert LLP
Davis+Gilbert LLP
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Davis+Gilbert LLP

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On December 26, 2024, the Fifth Circuit vacated the motion panel's order staying the injunction pending its consideration of the constitutionality of the CTA.

United StatesCorporate/Commercial Law
Mitchell W. Karsch
Mitchell W. Karsch
Justin Pollak
Justin Pollak
Marc Rogers Jr
Marc Rogers Jr
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The Bottom Line

  • Reversing course from its ruling on December 23, the Fifth Circuit Court of Appeals again put on hold the enforcement of the CTA.
  • With the nationwide preliminary injunction back in place (for now), reporting companies are not required to file BOI reports with FinCEN.
  • With the ongoing shifts in court rulings, reporting companies should proactively collect and maintain their beneficial ownership information to stay prepared in the event that filing requirements are, again, reinstated on short notice.

Timeline: Prior CTA Developments

  • December 3, 2024: The United States District Court for the Eastern District of Texas issued a nationwide preliminary injunction halting the enforceability of the Corporate Transparency Act (CTA) and its implementing regulations.

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