On December 23, 2024, the U.S. Fifth Circuit Court of Appeals in Texas Top Cop Shop, Inc., et al. v. Garland, et al, issued an order lifting the nationwide preliminary injunction against the enforcement of the CTA. In its ruling, the Fifth Circuit determined that the government had successfully demonstrated the nationwide injunction was not warranted. Following this Court of Appeals decision, reporting companies are now required to file beneficial ownership information with FinCEN, with extended deadlines due to the prior injunction. The new deadlines are as follows:
- Companies created or registered before January 1, 2024, must file by January 13, 2025 (previously January 1, 2025).
- Companies created or registered on or after September 4, 2024, with deadlines between December 3, 2024, and December 23, 2024, must file by January 13, 2025.
- Companies created or registered between December 3, 2024, and December 23, 2024, have an additional 21 days to file.
- Companies qualifying for disaster relief may have later deadlines.
- Companies created or registered on or after January 1, 2025, must file within 30 days after receiving notice of their registration.
Additionally, companies related to plaintiffs in the case National Small Business United v. Yellen are exempt from reporting at this time.
