Important - Corporate Transparency Act (Updated 12/31/24)

**TO ALL CMR CLIENTS**

Just days after lifting the nationwide injunction pending appeal, the merits panel of the U.S. Court of Appeals for the Fifth Circuit reinstated a nationwide injunction staying enforcement of the Corporate Transparency Act (“CTA”) and its reporting rules and regulations. The Fifth Circuit is reviewing the appeal on an expedited basis, and oral arguments are currently scheduled for March 25, 2025.  Other cases challenging the constitutionality of the CTA remain pending as well.

Pursuant to an alert posted on U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) website, reporting companies are not currently required to file beneficial ownership information and are not subject to liability if they fail to do so while this order remains in force. Reporting companies may continue to voluntarily submit beneficial ownership information reports and should carefully monitor any further developments.  Reporting companies that have not yet filed should continue compliance efforts and be prepared to act quickly to meet new deadlines should the injunction be overturned and the stay lifted, including preparing necessary reporting information and documentation for filing.

Please contact Melanie Roosa or Julianna Engel in our office at 845-565-1100 for any questions.