CTA Injunction Stayed Pending Appeal – Filings Now Required (Again)

On Dec. 23, 2024, the Fifth Circuit Court of Appeals issued a per curiam opinion in Texas Top Cop Shop v. Garland granting the government’s emergency motion for a stay pending appeal of the nationwide injunction that previously enjoined FinCEN’s enforcement of the Corporate Transparency Act. 

Pending further developments, the original deadlines as detailed below are back in place and reporting companies should submit their filings on or before such deadlines.

Further, entities who have already filed their reports will need to file amended reports within 30 days of any changes thereto.

The above deadlines are subject to the extensions granted to certain victims of Hurricane Milton, Hurricane Helene, Hurricane Debby, Hurricane Beryl, and Hurricane Francine as detailed here.

For additional background on the CTA, please see our overview of the Corporate Transparency Act here or reach out to any of the individuals listed below.