NEWSLETTERS

Important Update on FinCen BOI Filing Requirements – 2nd Injunction

January 24, 2025

Dear Client,

We want to inform you with the latest update regarding the Corporate Transparency Act (CTA) and the requirements for businesses to report Beneficial Ownership Information (BOI) to FinCEN.

Recently, the Supreme Court lifted a prior injunction that had temporarily halted enforcement of the BOI filing requirements. However, another nationwide injunction issued by a federal court in Texas remains in effect, which means the CTA’s BOI reporting requirements are still currently on hold.

We understand this situation may be confusing, especially given the involvement of both the Supreme Court and a lower court. Here’s a quick clarification:

  • The injunction lifted by the Supreme Court related to a specific legal challenge.
  • A separate case in Texas resulted in another injunction, issued by a different judge, which continues to block the implementation of the BOI filing requirements.

This type of legal overlap is not uncommon in cases involving complex federal laws, particularly when multiple legal challenges are filed across different jurisdictions. To read our full article on this click here.

Our Recommendation:

Even though the CTA is not being enforced at this time, we strongly recommend continuing to prepare your BOI reports if you have not already done so. Should the current injunction be lifted, it is likely that businesses will have only a very short window to comply with the requirements. Being prepared will help you avoid last-minute challenges and ensure compliance.

We are closely monitoring the situation and will keep you updated as developments unfold. In the meantime, if you have any questions about your BOI filing obligations or how to proceed, please don’t hesitate to reach out to our team at spteam@gpw.cpa.

Gatto, Pope & Walwick, LLP
Certified Public Accountants