Sharing an important update for you regarding a significant development that has occurred regarding the Corporate Transparency Act (CTA).
- On December 3, in the case Texas Top Cop Shop, Inc., et al. v. Garland, et al. at the U.S. District Court for the Eastern District of Texas, the Court issued a preliminary injunction. This ruling temporarily blocks the U.S. Department of Treasury from enforcing the CTA’s beneficial ownership information (BOI) reporting requirements.
- In response, FinCEN released additional guidance providing clarity on the impact of the court order. The guidance states: “In light of a recent federal court order, reporting companies are not currently required to file beneficial ownership information with FinCEN and are not subject to liability if they fail to do so while the order remains in force. However, reporting companies may continue to voluntarily submit beneficial ownership information reports.”
You can be confident that the CSC team is here to help and adapt as necessary as additional updates are communicated. As we shared last week when this decision was published, we’re here to support you—whether you choose to proceed with voluntary filings or await further clarity on these requirements.
We’ll continue to monitor developments closely and keep you informed as new guidance becomes available. For your reference, you can access the full memorandum opinion and order issued on
December 3 here.
Thank you for your continued partnership.
