On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of Treasury (Treasury) issued a new interim final rule (new IFR) significantly limiting the scope of reporting required under the...more
On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of Treasury (Treasury) significantly limited the scope of reporting required under the Corporate Transparency Act (CTA)....more
On March 3, 2025, a Michigan federal district court in Small Business Association of Michigan v Yellen, Case No. 1:24-cv-413 (W.D Mich 2025) (SBAM), held that the CTA’s reporting rule is unconstitutional under the Fourth...more
On March 2, 2025, the United States Department of Treasury announced that it will not enforce fines or penalties based on the existing deadlines for reporting beneficial ownership information under the CTA beneficial...more
On February 27, 2025, the U.S. Financial Crimes Enforcement Network (FinCEN) announced that it intends to issue an interim final rule by March 21, 2025, with extended beneficial ownership information reporting deadlines. It...more
On January 23, 2025, the United States Supreme Court (SCOTUS) reversed the U.S. district court’s preliminary injunction staying the Corporate Transparency Act (CTA) and the implementing Reporting Rule in Texas Top Cop Shop v...more
On February 19, 2025, the Financial Crime Enforcement Network (FinCEN) published an updated alert stating that, in view of the Smith district court’s decision lifting its nationwide stay of the CTA reporting rule, “beneficial...more
Late in the day on December 26, 2024, the United States Court of Appeals for the Fifth Circuit reinstated a nationwide injunction staying enforcement of the Corporate Transparency Act (CTA) and its reporting rules and...more
12/30/2024
/ Appeals ,
Beneficial Owner ,
Business Entities ,
Business Ownership ,
Corporate Transparency Act ,
Department of Justice (DOJ) ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reinstatement ,
Reporting Requirements ,
Stays ,
Time Extensions ,
Vacated
On December 23, 2024, in Texas Top Cop Shop, Inc. v. Merrick Garland, Civil Action No.4:24-CV-478 (5th Cir. 2024), the Fifth Circuit Court of Appeals lifted a nationwide preliminary injunction and stay of the U.S. Corporate...more
12/27/2024
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Beneficial Owner ,
Business Entities ,
Compliance ,
Corporate Transparency Act ,
Department of Justice (DOJ) ,
Filing Deadlines ,
Filing Requirements ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reporting Requirements ,
Stays ,
Time Extensions
On December 3, 2024, the U.S. District Court for the Eastern District of Texas issued a nationwide preliminary injunction temporarily enjoining the Corporate Transparency Act (CTA), 31 U.S.C. §5336 and its implementing...more
On March 1, 2024, an Alabama federal court declared the Corporate Transparency Act (CTA) unconstitutional—but only enjoined its enforcement as to the specific litigants.
As described in our prior alerts, the CTA...more
On July 22, 2022, the Office of the Inspector General of the U.S. Department of Health and Human Services (OIG) issued a Special Fraud Alert regarding transactions between practitioners and telemedicine companies. Aware that...more
UPDATED, APRIL 5, 2021: On March 30, 2021, President Biden signed the PPP Extension Act of 2021 into law extending the Paycheck Protection Program from March 31, 2021, to June 30, 2021. However, the SBA may not accept new...more
The SBA, in consultation with the Department of Treasury, has announced that it is reopening its portal for first draw and second draw PPP applications to all eligible PPP lenders today, January 19, 2021. The portal had...more
1/20/2021
/ CARES Act ,
Coronavirus/COVID-19 ,
Economic Injury Disaster Loans ,
Federal Loans ,
Financial Stimulus ,
Interim Final Rules (IFR) ,
Paycheck Protection Program (PPP) ,
Relief Measures ,
SBA ,
SBA Lending Programs ,
Small Business
On Thursday, October 29, 2020, Robert Gordon, Director of the Michigan Department of Health and Human Services, issued "Emergency Order Under MCL 333.2253 – Gatherings and Face Mask Order" ("Oct. 29 Order"). The Oct. 29...more
On October 9, 2020, the Director of the Michigan Department of Health and Human Services issued an emergency order reinstating some, but not all, of the restrictions contained in Governor Whitmer's COVID-19 emergency orders...more
While the loan forgiveness features of the Paycheck Protection Program loans (“PPP Loans”) have made PPP loans very attractive to eligible small businesses, borrowers wanting to take advantage of loan forgiveness need to...more
On April 23, 2020, Congress passed and President Donald Trump is expected to sign into law the “Paycheck Protection Program and Health Care Enhancement Act” (Act) to increase funding for paycheck protection program loans (PPP...more
4/24/2020
/ CARES Act ,
Coronavirus/COVID-19 ,
Economic Injury Disaster Loans ,
Federal Funding ,
Financial Institutions ,
FIRREA ,
Grants ,
Health Care Providers ,
Paycheck Protection Program (PPP) ,
Relief Measures ,
SBA ,
SBA Lending Programs
On March 27, 2020, Congress passed and President Donald Trump signed into law the $2.2 trillion "Coronavirus Aid, Relief, and Economic Security Act" (CARES Act) legislation aimed to provide economic relief from coronavirus...more
On March 27, 2020, Congress passed and President Donald Trump signed into law the $2.2 trillion "Coronavirus Aid, Relief, and Economic Security Act" (CARES Act) legislation aimed to provide economic relief from coronavirus...more