On December 3, 2024, the U.S. District Court for the Eastern District of Texas issued a nationwide preliminary injunction on the enforcement of the Corporate Transparency Act (CTA) reporting requirements for Beneficial Ownership Information (BOI). The reporting requirements that were otherwise required for most business owners effective January 1, 2024, have been challenged on the basis of being unconstitutional.

This is a preliminary injunction that temporarily suspends the enforcement of the CTA, any applicable penalties, and the reporting requirement itself.

What does this mean for you?

1. 1. Stay informed. Any further action by this court, the Fifth Circuit, or potentially the Supreme Court, may affect the preliminary injunction and your obligations under the CTA. Even once the court makes a final determination, the government may appeal the decision, as it has in the Alabama CTA case.
   2. No initial or updated filing requirement. At this time, you are not required to comply with the BOI reporting requirements (but if you already filed, that is fine).

Current status of filing
• Businesses formed before January 1, 2024, are not required to meet the January 1,         2025 BOI initial filing deadline.
• Businesses formed after January 1, 2024, are not required to file their initial BOI             report within the specified time period (90 days).
• Businesses are not required to file any updated BOI reports within 30 days of the           change of information.

1. 3. Be prepared. In the event the injunction is lifted or overturned, you must be prepared to file your BOI report as soon as possible to avoid any penalties.

We will continue to monitor the situation and provide you with additional information as it becomes available. Please let us know if you have any questions in the meantime.

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