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Thompson Hine LLP, a full-service business law firm with approximately 400 lawyers in 8 offices, was ranked number 1 in the category “Most innovative North American law firms: New working models” by The Financial Times and was 1 of 7 firms shortlisted for The American Lawyer’s inaugural Legal Services Innovation Award. The firm has been recognized by the National Law Journal as a Legal Technology Trailblazer and featured by Bloomberg for its innovative service delivery models, which drive accuracy and predictability. The firm’s commitment to innovation is embodied in Thompson Hine SmartPaTHTM – a smarter way to work – predictable, efficient and aligned with client goals. For more information, please visit ThompsonHine.com and ThompsonHine.com/SmartPaTH.

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<a></a><a></a><a></a><a></a><a></a><a>After many volleys in the </a>on-again, off-again ping pong match regarding reporting and enforcement under the Corporate Transparency Act (CTA), during the afternoon of January 23, 2025, the U.S. Supreme Court decided in the government’s favor and stayed the nationwide preliminary injunction against reporting under, and enforcement of, the CTA that was issued by the District Court for the Eastern District of Texas in early December 2024. This appears to mean the reporting requirements and enforcement of the CTA are once again in force.

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The government noted in its <a href="https://www.supremecourt.gov/DocketPDF/24/24A653/337159/20250113150232824_Texas%20Top%20Cop%20Shop%20Reply.pdf" target="_blank" rel="noreferrer noopener">reply brief filed with the Supreme Court</a> that FinCEN has informed the Solicitor General’s office at the Department of Justice that, if the Supreme Court “grants a stay, FinCEN would again briefly extend the deadline in light of the injunction’s having been in effect.” If this occurs, information on a grace period will likely be posted on its <a href="https://www.fincen.gov/boi" target="_blank" rel="noreferrer noopener">Beneficial Ownership Information web page</a>. However, with respect to potential daily monetary penalties for failing to comply ($606/day in 2025), the most conservative course of action is not to assume there will be a grace period to rely upon. This is especially true in light of the change of administration and uncertainty regarding new rules and regulations from federal government agencies.

You can find a copy of the order granting the stay of injunction <a href="https://aboutblaw.com/bgZN" target="_blank" rel="noreferrer noopener">here</a>, and the entire Supreme Court docket is available <a href="https://www.supremecourt.gov/search.aspx?filename=/docket/docketfiles/html/public/24a653.html" target="_blank" rel="noreferrer noopener">here</a> (note that as of the time of publication, it appeared the online traffic to this site was so high the docket may not show up; we suggest trying again later).

We will continue to monitor and provide updates as this matter evolves.

https://admin.thompsonhine.com/wp-content/uploads/2025/01/Thompson-Hine-Corporate-Law-Update-Supreme-Court-Says-CTA-Reporting-Enforcement-Back-On.pdf

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Supreme Court Says Corporate Transparency Act Reporting & Enforcement Back On

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