We apologize for the seemingly unending alerts about the Corporate Transparency Act (CTA) and its filing requirements; however, we want to be sure you are kept up to date as they develop.
In a turn of events, a separate panel of the Fifth Circuit of the US Court of Appeals, which previously issued a decision staying the preliminary injunction and reinstating the filing requirement for reporting companies under the CTA, has reversed course and restored the preliminary injunction pending appeal.
As a result, reporting companies are not currently required to comply with CTA reporting requirements and upcoming filing deadlines. However, given the unpredictability surrounding the status and enforceability of the CTA, it is prudent to voluntarily report beneficial ownership information to ensure compliance.
Attorneys at Barclay Damon will continue to monitor any judicial and legislative updates and further guidance from the Financial Crimes Enforcement Network regarding the CTA.
If you have any questions regarding the content of this alert, please contact Danielle Katz, counsel, at dkatz@barclaydamon.com; Karina Shahine, associate, at kshahine@barclaydamon.com; or another member of the firm’s Corporate Practice Area.