March 2, 2025 UPDATE: As this case against the CTA has been on a roller coaster ride in 2025, I am including a link to the latest updates from CAI that can be read HERE as well as the March 2, 2025 statement made by the U.S. Treasury that can be read HERE. This update was in an email notice that was sent out to all CAI members from Thomas M. Skiba, CEO of CAI.
Prior to the March update, on February 27, 2025 FinCEN announced that they will not be issuing any fines, penalties, or take any further enforcement actions against an entity that fails to file or provide updates to beneficial ownership information (BOI) filed with FinCEN under the CTA by the deadlines that are currently in place. The March update by the U.S. Treasury takes this a step further in backing off of enforcement measures with the following snippet from their official statement:
“…not only will it not enforce any penalties or fines associated with the beneficial ownership information reporting rule under the existing regulatory guidelines, but it will further not enforce any penalties or fines against U.S. citizens or domestic reporting companies or their beneficial owners after the forthcoming rule changes take effect either.”
The full statement from the U.S. Treasury says they will be issuing a propose rule to narrow the scope of the CTA to foreign reporting companies only. This new ruling is being interpretated by CAI to mean the CTA and its reporting requirements are no longer in effect for U.S. citizens or domestic reporting companies, including all applicable community associations.
As the suit filed by CAI is still working its way through the courts, I am sure there will be more updates to report in the coming weeks and months. Stay tuned!!
PRIOR UPDATES:
Once again The Corporate Transparency Act is making headlines before its implementation, which has now had the filing deadline put on hold (again) by the Fifth Circuit Court of Appeals, which has led FinCEN to release a statement for reporting companies to file their initial beneficial ownership information (BOI) reports with FinCEN that the BOI filings are now voluntary.
The Corporate Transparency Act has been the subject of some recent legal action taken by CAI in hopes of preventing this Act from impacting over 300,000 associations across the United States from being adversely impacted as of January 1, 2025. The most recent actions taken by the US District Court for the Eastern District of Texas in the matter of Texas Top Cop Shop, Inc et al. v. Garland et al can be found HERE or on the weblink below.
To learn more about what work is being done by CAI regarding the Corporate Transparency Act, please click on the links below to learn more:
Breaking News (12/26/24): CTA Filing Requirements Paused Again by Fifth Circuit
UPDATE 12/23/24 – CTA National Update: Filing Deadline Reinstated With Deadline Extensions
UPDATE 12/3/24 – Preliminary Nationwide Injunction Filed in US District Court in Texas
Corporate Transparency Act — Advocacy Priorities Overview
10/2/2024 — CAI Sends White Paper to US Department of Treasury on CTA
Nov 2014 – CAI reports preliminary injunction filed has been denied / CTA Updates and Resources
