News & Analysis as of

Regulatory Requirements Time Extensions

Womble Bond Dickinson

FTC Defers Some Click-to-Cancel Rule Enforcement to July 14, 2025

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Companies with recurring payment programs with negative option terms now have until July 14, 2025, to bring their disclosure, consent, and cancellation practices into full compliance....more

Cozen O'Connor

Deadline Extended for New York City Local Law 97

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May 1, 2025, was the first compliance report deadline under New York City’s Local Law 97 (LL97). LL97 requires most buildings over 25,000 square feet, including condominiums (condos) and cooperatives (coops), to limit carbon...more

Venable LLP

The FTC Defers Compliance Deadline for Updated Negative Option Rule to July 14 - A Fast VAST Update​​

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On Friday, ​the Federal Trade Commission voted to defer the compliance deadline for the amended Negative Option Rule by 60 days. The Commission issued a statement on the new deadline....more

BakerHostetler

FTC Delays Enforcement of Negative Option Rule Until July 14

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The Federal Trade Commission (FTC) released a statement on May 9 deferring by 60 days its enforcement of certain provisions of the Negative Option Rule (the Rule). The bulk of the Rule’s requirements are now scheduled to go...more

Venable LLP

FCC Approves Narrow Delay of New TCPA Revocation Rule

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On April 7, the Federal Communications Commission (FCC) granted a limited waiver delaying by an additional year the effective date of certain parts of the new Telephone Consumer Protection Act (TCPA) rule. ...more

Troutman Pepper Locke

FCC Grants Limited One-Year Extension for TCPA Robocall Revocation Rule Compliance

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The Federal Communications Commission (FCC) issued an order extending the effective date of certain parts of § 64.1200(a)(10) of its rules under the Telephone Consumer Protection Act (TCPA) to April 11, 2026....more

BCLP

Pause for Effect: Current Corporate Transparency Act Deadlines will not be Enforced

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Although the Corporate Transparency Act (the “CTA”) remains in full force and effect and, along with it, a requirement for most reporting companies to file their beneficial ownership information reports, the previously...more

BakerHostetler

CTA Back in Effect; New Reporting Deadline of March 21

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On Feb. 17, the Texas federal district court in Smith v. U.S. Department of the Treasury granted the government’s motion for an immediate stay pending appeal of the nationwide order staying the effective date of the final...more

WilmerHale

Corporate Transparency Act: It’s Still Paused (For Now)

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Entities subject to the Corporate Transparency Act’s beneficial ownership information reporting requirement are not currently required to file BOI reports. Beyond that, much remains in flux regarding whether and when...more

Ruder Ware

The CTA Journey – It Goes On and On and On

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The Corporate Transparency Act (“CTA”) has been on a journey this past month with a whirlwind of court rulings: halted by a federal district court, reinstated by the Fifth Circuit’s motions panel, had its reporting deadlines...more

Sullivan & Worcester

Breaking: Corporate Transparency Act on Hold Again

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Late on December 26, 2024, the U.S. Court of Appeals for the Fifth Circuit reversed its own decision from earlier in the week, reinstating the nationwide preliminary injunction preventing the enforcement of the Corporate...more

UB Greensfelder LLP

Fifth Circuit Court of Appeals Reinstates Nationwide Injunction Blocking Enforcement of the Corporate Transparency Act

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On December 26, 2024, the Fifth Circuit Court of Appeals reinstated the nationwide preliminary injunction blocking enforcement of the Corporate Transparency Act (CTA). This decision was made to "preserve the constitutional...more

Parker Poe Adams & Bernstein LLP

Corporate Transparency Act Filings Are Back on Hold

In an unusual turn of events, the Fifth Circuit Court of Appeals has reversed itself and put the Corporate Transparency Act (CTA) back on hold....more

Eversheds Sutherland (US) LLP

Fifth Circuit changes course—CTA preliminary injunction reinstated

On December 26, 2024, the US Court of Appeals for the Fifth Circuit changed course, effectively reinstating the preliminary injunction enjoining enforcement of the Corporate Transparency Act (CTA)....more

Benesch

On Hold AGAIN - CTA Preliminary Injunction Reinstated

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As we previously reported, on December 3, 2024, the U.S. District Court for the Eastern District of Texas issued a nationwide preliminary injunction blocking the U.S. Department of Treasury from enforcing the Corporate...more

Miller Canfield

Fifth Circuit Reinstates Texas Federal District Court’s Nationwide Preliminary Injunction and Stay of the Corporate Transparency...

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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

Holland & Knight LLP

Corporate Transparency Act: Nationwide Injunction in Place Again; All Filing Deadlines Suspended

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In a continuing series of dizzying judicial actions, the U.S. Court of Appeals for the Fifth Circuit on Dec. 26, 2024, vacated the stay and reinstated the nationwide preliminary injunction enjoining enforcement of the...more

Venable LLP

Fifth Circuit Reimposes Nationwide Preliminary Injunction

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After a rollercoaster ride last week, the Corporate Transparency Act's (CTA) nationwide preliminary injunction remains in place for the immediate future, pending further review by the U.S. Court of Appeals for the Fifth...more

Bass, Berry & Sims PLC

Fifth Circuit Reinstates Injunction Halting Enforcement of Corporate Transparency Act

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On December 26, 2024, the U.S. Court of Appeals for the Fifth Circuit issued an unsigned order in Texas Top Cop Shop, Inc. v. Garland, No. 24-40792,  reversing its prior December 23 order lifting the preliminary injunction...more

Bradley Arant Boult Cummings LLP

Should I Stay or Should I Go? Reporting Companies Are (Again) Not Required to Comply with the CTA

Here’s a brief recap of the CTA drama to date: On December 3, 2024, in the case of Texas Top Cop Shop, Inc., et al. v. Garland, et al., the U.S. District Court for the Eastern District of Texas found the Corporate...more

Foley Hoag LLP

Fifth Circuit Reinstates Nationwide Preliminary Injunction that Enjoined Reporting and Enforcement Under The Corporate...

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In a highly unusual and unexpected order, late on December 26, 2024, a “merits panel” of the Fifth Circuit (made up of different judges than the “motions panel” that stayed the nationwide preliminary injunction on December...more

Spilman Thomas & Battle, PLLC

Corporate Transparency Act Nationwide Injunction Reinstated

If you are feeling a bit of whiplash today, you are not alone. The United States Court of Appeals for the Fifth Circuit has reinstated a preliminary nationwide injunction of the Corporate Transparency Act (“CTA”)....more

Tucker Arensberg, P.C.

UPDATE: Corporate Transparency Act  (“CTA”) Enforcement Once Again On Hold

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As of December 26, 2024, the nationwide injunction that had been lifted only days ago has been put back in effect. This means that reporting requirements under the Corporate Transparency Act may not be enforced for the time...more

BakerHostetler

Nationwide CTA Injunction Is Back in Effect. What Happens Now?

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In yet another twist, the CTA is again currently enjoined (for now). On Dec. 26, in a highly unusual chain of events, the merits panel of the Fifth Circuit Court of Appeals vacated the emergency stay granted by the motions...more

McGlinchey Stafford

Game On: Preliminary Injunction on Corporate Transparency Act Lifted; Filing Deadlines Extended

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The United States Court of Appeals for the Fifth Circuit on December 23, 2024, issued an order lifting a prior order issued by a federal district court in the Eastern District of Texas granting a nationwide preliminary...more

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