On December 23, 2024, the Fifth Circuit issued an order granting a stay of the December 3 nationwide injunction against the Corporate Transparency Act (CTA) that was originated in the U.S. District Court for the Eastern District of Texas. Effective immediately, the CTA’s beneficial ownership reporting requirements are reinstated. The Fifth Circuit order did not delay any reporting deadlines, and FinCEN has not released any statement on the matter.

Given that the government’s reasoning in requesting a stay of the nationwide injunction was in order to enforce its previously existing deadline of December 31, 2024, reporting companies are advised to file Beneficial Ownership Information (BOI) Reports by the deadline and comply with the CTA as they had done before the December 3 nationwide injunction.

We will continue to monitor the developments in this arena, including any public statements from FinCEN, regarding applicable reporting deadlines.