UPDATE AS OF JANUARY 24, 2025
On Thursday, January 23, 2025, as part of the ongoing roller coaster of legal challenges to the Corporate Transparency Act (“CTA”), the U.S. Supreme Court lifted an injunction issued by the district court in Texas Top Cop Shop, Inc., allowing the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) to proceed with enforcing the requirement for reporting companies, including community associations, to file Beneficial Ownership Information (“BOI”) with FinCEN.
The prior injunction temporarily blocked enforcement of the CTA, making the filing completely voluntary. Yesterday’s ruling allows the government to proceed with enforcement of the CTA during the pendency of the legal challenges.
At the time of preparing this update, FinCEN has not provided an updated compliance deadline. Note that reporting companies located several counties in Florida may still qualify for disaster relief extensions.
On a practical level, many may be wondering when to file their Initial BOIR in light of the constantly changing environment surrounding the CTA. While the situation is extremely fluid, community association board members who have not yet filed their initial BOI reports, and/or those that may need to file updated reports, should gather the necessary information to file/update their BOI within the timeframes established by FinCen.
We will continue to monitor all legal developments and provide updates as they become available.
Should you have any questions regarding the recent court ruling or the CTA in general, please contact our office via CTA@eisingerlaw.com.