FinCEN has filed motions in both the Eastern District of Texas and the Fifth Circuit asking the Courts to stay the nationwide preliminary injunction against the enforcement of the Corporate Transparency Act (“CTA”) during its appeal of the injunction. In its filing in the Fifth Circuit, FinCEN asked the Court to rule no later than December 27 to allow reporting companies to comply with their obligations under the CTA by December 31.
At this point, the best practice is to have your Beneficial Ownership Information Report ready to file if either Court lifts the stay.
PSE attorneys continue monitoring the ongoing litigation and will provide updates to inform you of your obligations to comply with the CTA. If you have questions regarding the Corporate Transparency Act or what this preliminary injunction means for your company, please get in touch with Katie Wahl at kwahl@pselaw.com or (937) 223-1130.