We end 2024 and begin 2025 with yet another Corporate Transparency Act update!  The full panel of the 5th Circuit Court of Appeals temporarily overruled the earlier stay issued by the Court of Appeals’ three judge panel, which previously overruled the District Court’s preliminary injunction of the enforcement of the January 1, 2025, deadline for reporting compliance under the CTA.   What all these judicial rulings mean is CTA compliance filings are again permitted, but not required, to be completed by the previously extended January 13, 2025, deadline. 

While the injunction is again in effect, because the original 5th Circuit panel indicated it believes the law is constitutional, it is likely the CTA filing deadline will be reinstated in the future.  It is just a matter of when.  In light of that, we continue to recommend that associations who have not yet reported to FinCen do so before January 13, 2025.

We have been regularly updating our clients on CTA developments.  K&C clients that have already completed their information through our portal in ATLAS, you are in compliance regardless of the outcome of this case and no further action is needed.   If you are not a K&C client and would like additional information about our services and how we can help with understanding this information, please reach out to us and Request for Proposal.