Corporate Transparency Act Requirements Reinstated

By Michael High, Brittany Michaud, and Andrew Sweeney

December 24, 2024

As previously reported, a United States District Court recently instituted a nation-wide ban on the enforcement of the Corporate Transparency Act. The ban was lifted in a decision by the Fifth Circuit Court of Appeals issued on Monday, December 23, 2024.  As a result, if you are a reporting company, your CTA reporting obligations have been reinstated and you must comply with FinCEN’s updated deadlines by filing your beneficial ownership information (BOI) report as follows:

Reporting companies that were created or registered:

• prior to January 1, 2024 must file their BOI report by January 13, 2025 (the previous deadline was January 1, 2025);
• on or after September 4, 2024 that had a filing deadline of December 3, 2024 to December 23, 2024 have until January 13, 2025 to file their BOI report; and
• on or after December 3, 2024 and on or before December 23, 2024 have an additional 21 days from their original filing deadline to file their BOI report.

If you have any questions, please contact your principal at Drummond Woodsum and more generally you may want to consult our prior alerts which can be found at: Get Ready for the Corporate Transparency Act – Drummond Woodsum; The CTA: Time is Running Out – Drummond Woodsum; UPDATE on the Corporate Transparency Act – Drummond Woodsum.