On December 26th 2024, the U.S. 5th Circuit court has continued the injunction against the Corporate Transparency Act (CTA), temporarily halting enforcement of the beneficial ownership reporting requirements, including the January 13, 2025 deadline. This injunction is widely believed to apply nationwide, including community associations and other owners’ associations.
Please note, a preliminary injunction is not a final decision. It is expected that the government will continue to litigate.
FinCEN may also issue guidance on this case. We will keep you updated on any new developments.
CTA Review Client Options:
- Continue with the process: Proceed with collecting information and filing with FinCEN.
- Hold filing: Continue collecting information and preparing the BOI report, but hold off on filing until the injunction is lifted.
- Pause the process: Stop all collection efforts and wait to see how the situation develops.
There are many differing legal opinions and numerous unknown factors at play. To maintain the high level of service our clients deserve, we are invoicing for all files. This ensures we can continue to collect information and be prepared to file if needed. Some clients prefer to proceed with filing now rather than wait. If the injunction is overturned in the coming weeks, there may be a rush to comply. However, it’s also possible that the injunction remains in place.
For specific guidance, we recommend consulting your HOA’s legal counsel.
If we do not receive a Hold or Pause request through our webform below, we will proceed with Option 1 and continue the process as planned.