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Reporting Requirements FinCEN Filing Requirements

Quarles & Brady LLP

Annual Update of Form ADV and Recent Regulatory Changes Affecting Advisers (UPDATED)

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As a reminder, each registered investment adviser must file an annual updating amendment to its Form ADV within 90 days of its fiscal year end. This means an adviser with a December 31 fiscal year end will be required to file...more

Orrick, Herrington & Sutcliffe LLP

Corporate Transparency Act Beneficial Reporting Still on Hold Nationwide – Stay Tuned

On January 23, 2025, the U.S. Supreme Court vacated one nationwide stay (Texas Top Cop Shop, Inc. v. McHenry – formerly, Texas Top Cop Shop v. Garland) which blocked the U.S. government from enforcing the Corporate...more

Amundsen Davis LLC

Another Twist in the Corporate Transparency Act Saga: FinCEN Announces That Ownership Information Reporting Is Not Currently...

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The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced in an alert posted on its website on January 24, 2025, that reporting companies under the Corporate Transparency Act (CTA) are not...more

Warner Norcross + Judd

CTA Filing Obligations Remain Voluntary Amid Court Challenges

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After a few days on a legal roller coaster, enforcement and reporting obligations under the Corporate Transparency Act (CTA) remain on hold as lawsuits challenging the CTA’s constitutionality continue. On Jan. 23, 2025, the...more

Mayer Brown

Not Quite Yet: Supreme Court Stays CTA Injunction, But Filing Requirements Remain Suspended

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AT A GLANCE - The US Supreme Court has stayed the injunction against the Corporate Transparency Act (CTA), but the requirement for companies to file beneficial ownership information remains suspended, creating ongoing...more

Verrill

Status of CTA Reporting Rule as of January 24, 2025

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FinCEN announced on January 24: In light of a recent federal court order, reporting companies are not currently required to file beneficial ownership information with FinCEN and are not subject to liability if they fail to...more

Moore & Van Allen PLLC

Corporate Transparency Act Reporting Obligations Remain Paused Despite Supreme Court Order

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On January 23, 2025, the United States Supreme Court ruled on McHenry v. Texas Top Cop Shop, Inc., granting the Government’s application to stay the injunction of the Corporate Transparency Act (“CTA”) initially ordered by...more

Baker Donelson

CTA Filings Remain Voluntary... For Now

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A flurry of activity in the courts and guidance from FinCEN this week has the Corporate Transparency Act back in the news. However, the recent activity does not result in any immediate change for businesses. Filing beneficial...more

McDermott Will & Emery

Corporate Transparency Act Update: Nationwide Injunction Continues

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On January 23, 2025, the Supreme Court of the United States issued a stay of the nationwide preliminary injunction against enforcement of the Corporate Transparency Act (CTA) (31 U.S.C. § 5336) and the Beneficial Ownership...more

McCarter & English, LLP

The Evolution of the CTA: BOIR Filing Still Voluntary (For Now)

Jaunary 23, the US Supreme Court (SCOTUS) issued a highly anticipated decision with respect to the reporting requirements and enforcement of the Corporate Transparency Act (31 U.S.C. § 5336, the CTA). As summarized below, a...more

McGlinchey Stafford

Game On – Again, Not Exactly: Supreme Court Stays CTA Universal Injunction

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The rollercoaster has more hills and turns. On January 23, 2025, the U.S. Supreme Court agreed that the Government is entitled to a stay of the universal injunction of the Corporate Transparency Act (CTA). In light of this...more

Cole Schotz

CTA Update: Companies Not Required To File Under The CTA, Despite Supreme Court Stay

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Despite a Supreme Court order issued on January 23, 2025, as of January 24, 2025, FinCEN has stated they are not requiring companies to file under the CTA. On January 23, 2025, the U.S. Supreme Court, in an unsigned order,...more

Rivkin Radler LLP

SCOTUS Hands Down CTA Decision — FinCEN Says Reporting Requirements Remain on Pause

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The Financial Crimes Enforcement Network (“FinCEN”) announced on Friday, January 24, 2025, that reporting companies are not currently required to file beneficial ownership information (“BOI”) under the Corporate Transparency...more

Kilpatrick

Corporate Transparency Act Still Enjoined Despite Recent Supreme Court Ruling

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We previously reported that on December 26, 2024, a panel of the United States Court of Appeals for the Fifth Circuit restored the nationwide preliminary injunction against enforcement of the federal Corporate Transparency...more

Stradling Yocca Carlson & Rauth

Navigating the Complexities of CTA Compliance: What You Need to Know - UPDATED

UPDATE: Please note there is a preliminary injunction against enforcement of the Corporate Transparency Act.  The injunction, which applies nationwide, was granted by a Texas federal district court and such injunction has...more

Ruder Ware

The CTA Journey – It Goes On and On and On

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The Corporate Transparency Act (“CTA”) has been on a journey this past month with a whirlwind of court rulings: halted by a federal district court, reinstated by the Fifth Circuit’s motions panel, had its reporting deadlines...more

Sheppard Mullin Richter & Hampton LLP

Fifth Circuit Court of Appeals Vacates Its Own Stay Rendering the Corporate Transparency Act Unenforceable . . . Again

On December 26, 2024, in Texas Top Cop Shop, Inc. v. Garland, No. 24-40792, 2024 WL 5224138 (5th Cir. Dec. 26, 2024), a merits panel of the United States Court of Appeals for the Fifth Circuit issued an order vacating the...more

Sullivan & Worcester

Breaking: Corporate Transparency Act on Hold Again

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Late on December 26, 2024, the U.S. Court of Appeals for the Fifth Circuit reversed its own decision from earlier in the week, reinstating the nationwide preliminary injunction preventing the enforcement of the Corporate...more

BCLP

Corporate Transparency Act Update: FinCEN Asks SCOTUS to Intervene

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As previously reported, on December 26, 2024, the Fifth Circuit first lifted—and then reinstated—a preliminary nationwide injunction staying the Corporate Transparency Act’s (“CTA”) reporting requirements pending appeal....more

Bodman

Federal Court Reinstates Injunction Against Enforcement of Corporate Transparency Act

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On December 26, 2024, the Fifth Circuit Court of Appeals vacated its earlier stay of the injunction suspending the reporting deadlines for the Corporate Transparency Act (the “CTA”)....more

UB Greensfelder LLP

Fifth Circuit Court of Appeals Reinstates Nationwide Injunction Blocking Enforcement of the Corporate Transparency Act

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On December 26, 2024, the Fifth Circuit Court of Appeals reinstated the nationwide preliminary injunction blocking enforcement of the Corporate Transparency Act (CTA). This decision was made to "preserve the constitutional...more

Womble Bond Dickinson

Update: CTA Filing Requirements Are "On" - Compliance Required by January 13, 2025 (for most reporting companies)

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On December 23, 2024, the Court of Appeals for the Fifth Circuit stayed the nationwide injunction enjoining the U.S. government from enforcing the Corporate Transparency Act (the “CTA”) and the corresponding reporting...more

BCLP

To File, or Not to File: the Fifth Circuit’s Evolving Treatment of the Corporate Transparency Act

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The U.S. Court of Appeals for the Fifth Circuit reinstated and then subsequently suspended the reporting requirements under the Corporate Transparency Act (the “CTA”) over the course of the last week by staying the original...more

Womble Bond Dickinson

CTA UPDATE: No Action Needed Yet - Mandatory CTA Filings are “OFF” For Now

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On December 26, 2024, the Court of Appeals for the Fifth Circuit VACATED a ruling early this week to stay the nationwide injunction enjoining the U.S. government from enforcing the Corporate Transparency Act (the “CTA”) and...more

Burr & Forman

Corporate Transparency Act Halted (Again): What’s Happened and What’s Next?

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What happened now? On December 26, 2024, and only three 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...more

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