Client Alert

As reported in our recent series of Client Alerts,1 on December 3, 2024, the U.S. District Court for the Eastern District of Texas (the “District Court”) issued a nationwide preliminary injunction that temporarily blocked enforcement of the Corporate Transparency Act (“CTA”) and the U.S. Department of the Treasury's Financial Crimes Enforcement Network’s (“FinCEN”) related beneficial ownership information (“BOI”) reporting rules. On December 23, 2024, the Fifth Circuit Court of Appeals (the “Court of Appeals”) granted the government’s motion to stay the District Court’s preliminary injunction pending its appeal of that injunction order. As a result of the Court of Appeal’s ruling, FinCEN extended the reporting deadline to January 13, 2025. 

Update as of December 26, 2024

By a brief order dated December 26, 2024, the Court of Appeals reversed itself and vacated its prior order which had granted a stay of the preliminary injunction, leaving the nationwide preliminary injunction in place. The Court of Appeals has set a hearing for the matter on March 25, 2025.   

Accordingly, as of the date of this Client Alert, the CTA and the BOI reporting requirements are again enjoined by the District Court’s nationwide preliminary injunction. However, given the unpredictable nature of this case, all reporting companies should remain prepared to comply with the CTA’s BOI reporting requirements pending further decision by the Court of Appeals.

We are closely monitoring developments in this rapidly changing case and will continue to provide updates.

  1. See the following Client Alerts for a history of recent developments regarding enforcement of the Corporate Transparency Act:
    December 9, 2024: “Corporate Transparency Act Enforcement Temporarily Blocked by Court”
    December 13, 2024: FinCEN Seeks Stay of Corporate Transparency Act Preliminary Injunction”
    December 17, 2024: “Government Files an Emergency Motion with the 5th Circuit Court of Appeals to Stay Corporate Transparency Act Preliminary Injunction”
    December 23, 2024: “Fifth Circuit Court of Appeals Grants Stay Pending Appeal as to the Preliminary Injunction of the Corporate Transparency Act, and FinCEN Extends CTA Reporting Deadline to January 13, 2025”

We have always been focused on finance.

  • 1913
    TS Chapman partners with Henry Cutler to form Chapman and Cutler
  • 1st
    Chapman's first client in 1913 is still a client of the firm today
  • 22
    Diverse financial practices serving regional, national, and global clients
  • 6
    Offices across the country and in key US financial centers

Chapman and Cutler LLP Cookie Preference Center

Your Privacy

When you visit our website, we use cookies on your browser to collect information. The information collected might relate to you, your preferences, or your device, and is mostly used to make the site work as you expect it to and to provide a more personalized web experience. For more information about how we use Cookies, please see our Privacy Policy.

Strictly Necessary Cookies

Always Active

Necessary cookies enable core functionality such as security, network management, and accessibility. These cookies may only be disabled by changing your browser settings, but this may affect how the website functions.

Functional Cookies

Always Active

Some functions of the site require remembering user choices, for example your cookie preference, or keyword search highlighting. These do not store any personal information.

Form Submissions

Always Active

When submitting your data, for example on a contact form or event registration, a cookie might be used to monitor the state of your submission across pages.

Performance Cookies

Performance cookies help us improve our website by collecting and reporting information on its usage. We access and process information from these cookies at an aggregate level.

Powered by Firmseek