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Sheppard Mullin Richter & Hampton LLP

CFPB Halts Enforcement of Small Business Lending Rule for Institutions Outside Fifth Circuit

On April 30, the CFPB announced it will deprioritize enforcement and supervision of its small business lending data collection rule for institutions not covered by the stay issued by the U.S. Court of Appeals for the Fifth...more

Parker Poe Adams & Bernstein LLP

Corporate Transparency Act Reporting Requirements Are Back: New March 21 Deadline

In the latest twist involving the Corporate Transparency Act (CTA), the only nationwide injunction still in effect that barred enforcement of the CTA’s filing deadlines (Smith vs. U.S. Department of the Treasury) was stayed...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

Pullman & Comley, LLC

The Corporate Transparency Act is Back (For Now): Texas Court Lifts Final Nationwide Injunction Against the CTA

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The Corporate Transparency Act (CTA) and its beneficial ownership information (BOI) reporting requirements are back in effect. On Monday, February 18, 2025, a federal district court in Texas granted a stay of the nationwide...more

Stinson LLP

An Uncertain Future for CFPB's Section 1071 Rule Regarding Small Business Lending Data

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In a pivotal development, the U.S Court of Appeals for the Fifth Circuit has stayed enforcement of the Consumer Financial Protection Bureau’s (CFPB) Small Business Lending Rule — also known as Section 1071 of the Dodd-Frank...more

Ballard Spahr LLP

Appeals Court stays small business reporting rule for many financial institutions

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The Fifth Circuit Court of Appeals has issued a stay that blocks for many financial institutions the implementation of a CFPB rule that requires the institutions to report information contained in loan applications submitted...more

Neal, Gerber & Eisenberg LLP

DOJ Seeks to Reinstate Corporate Transparency Act

On February 5, 2025, the Department of Justice (DOJ) filed a notice of appeal and motion for stay of the injunction against enforcement of the Corporate Transparency Act (CTA) issued by the Eastern District of Texas in Smith...more

IR Global

Beneficial Ownership Reporting – To File or Not to File?

IR Global on

Considering conflicting rulings, businesses remain understandably confused about whether to file their mandated Beneficial Ownership Reports with FinCen. As of this writing, the answer remains that businesses may file but are...more

Seyfarth Shaw LLP

FinCEN Issues Further Guidance on Pausing CTA Compliance in Response to Supreme Court Ruling

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January 24, 2025 Update: On January 24, FinCEN published updated reporting guidance in which it announced that reporting companies are not currently required to file beneficial ownership information with FinCEN despite the...more

Warner Norcross + Judd

CTA Filing Obligations Remain Voluntary Amid Court Challenges

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After a few days on a legal roller coaster, enforcement and reporting obligations under the Corporate Transparency Act (CTA) remain on hold as lawsuits challenging the CTA’s constitutionality continue. On Jan. 23, 2025, the...more

Morrison & Foerster LLP

The Ping-Pong Continues – But CTA Is Still on Hold

On January 23, 2025, the U.S. Supreme Court granted the federal government’s motion to stay the nationwide injunction blocking the Corporate Transparency Act’s (CTA) enforcement, issued by the federal district court of the...more

Fenwick & West LLP

The Corporate Transparency Act: Reporting Obligations Remain Paused Despite Recent Court Developments

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Companies are still not required to comply with the Corporate Transparency Act (CTA)—despite a U.S. Supreme Court ruling on Thursday suggesting otherwise. On January 23, the High Court stayed a December 3 injunction in...more

Cozen O'Connor

A CTA Injunction Remains Despite Supreme Court Stay

Cozen O'Connor on

On January 23, 2025, the U.S. Supreme Court stayed the injunction issued by the Fifth Circuit Court of Appeals in the case of Texas Top Cop Shop, Inc. v. Garland, et al. Case No. 4:24-cv-478 (E.D. Tex.) (Texas Top Cop Case)....more

McGlinchey Stafford

Game On – Again, Not Exactly: Supreme Court Stays CTA Universal Injunction

McGlinchey Stafford on

The rollercoaster has more hills and turns. On January 23, 2025, the U.S. Supreme Court agreed that the Government is entitled to a stay of the universal injunction of the Corporate Transparency Act (CTA). In light of this...more

Hinshaw & Culbertson LLP

UPDATE: SCOTUS Stayed a CTA Injunction Under the "Texas Top Cop Shop" Action, BUT the CTA is Still NOT Back in Effect

In the latest twist on the back-and-forth CTA battle, on January 23, 2025, the Supreme Court of the United States (SCOTUS) once again stayed (i.e., suspended the effect of) the nationwide preliminary injunction against...more

Wiley Rein LLP

CTA Update: Supreme Court Temporarily Lifts Injunction, but Requirements Remain Blocked

Wiley Rein LLP on

On January 23, 2025, the U.S. Supreme Court issued a ruling that appears to settle – for now – a nearly two-month-long legal battle over the Corporate Transparency Act (CTA), which began with a nationwide preliminary...more

Maynard Nexsen

FinCEN Confirms Compliance with Corporate Transparency Act Remains Voluntary

Maynard Nexsen on

In response to the Supreme Court’s opinion released yesterday granting the government’s motion to stay the nationwide injunction issued in Texas Top Cop Shop, Inc. v. McHenry, the Financial Crimes Enforcement Network...more

Pullman & Comley, LLC

Despite Supreme Court Granting Stay, CTA Enforcement Remains Paused

Pullman & Comley, LLC on

On January 23, 2025, it appeared that the Supreme Court had given the green light to FinCEN to resume enforcement of the Corporate Transparency Act (CTA) and its beneficial ownership information reporting requirements after...more

Foley & Lardner LLP

Corporate Transparency Act Enforcement Remains Paused

Foley & Lardner LLP on

On January 23, 2025, the U.S. Supreme Court issued a stay of the nationwide preliminary injunction issued by a federal district court in Texas in December 2024 in the Texas Top Cop Shop litigation....more

Katten Muchin Rosenman LLP

Corporate Transparency Act Reporting Remains Voluntary

This Corporate Advisory provides a brief update on recent litigation regarding the Corporate Transparency Act (CTA) and its reporting requirements. It is not intended to, and does not, provide legal, compliance or other...more

Allen Matkins

The CTA Is Dealt Another Blow

Allen Matkins on

As has been widely reported, U.S. District Court Judge Amos L. Mazzant in early December of last year preliminarily enjoined the CTA and its implementing regulations.  Texas Top Cop Shop, Inc. v. Garland, 2024 WL 5049220...more

Stradling Yocca Carlson & Rauth

Navigating the Complexities of CTA Compliance: What You Need to Know - UPDATED

UPDATE: Please note there is a preliminary injunction against enforcement of the Corporate Transparency Act.  The injunction, which applies nationwide, was granted by a Texas federal district court and such injunction has...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

Sheppard Mullin Richter & Hampton LLP

Fifth Circuit Court of Appeals Vacates Its Own Stay Rendering the Corporate Transparency Act Unenforceable . . . Again

On December 26, 2024, in Texas Top Cop Shop, Inc. v. Garland, No. 24-40792, 2024 WL 5224138 (5th Cir. Dec. 26, 2024), a merits panel of the United States Court of Appeals for the Fifth Circuit issued an order vacating the...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

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