Update 3/27/25 : In a win for NAHB and the small business community, the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) published an interim final rule on beneficial ownership information (BOI) reporting requirements that narrows the BOI reporting requirements to foreign reporting companies only. The rule states that domestic reporting companies “are exempted from the reporting requirements and do not have to report BOI to FinCEN, or update or correct BOI previously reported to FinCEN. Read More Here
Update 3/3/25 : Yesterday the US Treasurey Department says it will not enforce any penalities under the act against US Citizens or domestic reporting companies. For more information you can read more here.
Update 1/23/25: On January 23, 2025, the U.S. Supreme Court granted the Application for Stay of the Amended Order of the U.S. District Court, E.D. Texas, issued December 5, 2025 in Texas Top Cop Shop, Inc. v. Garland, No. 4:24-CV-478, 2024, that enjoined enforcement of the Corporate Transparency Act. The U.S. Supreme Court stayed the order pending disposition of the appeal in the Fifth Circuit Court of Appeals and disposition of a petition for writ of certiorari, if such a writ is timely sought.
Justice Gorsuch concurred in the stay, but indicated he would go a step further and take the case now as the government suggested, to resolve definitively whether a district court may issue universal injunctive relief. Justice Jackson dissented, opining that emergency relief is not appropriate because the applicant failed to demonstrate sufficient exigency to justify the intervention of the U.S. Supreme Court.
The decision of the U.S. Supreme Court means that enforcement of CTA requirements will proceed. As of this writing, new guidance has not been issued by FinCEN. Please refer to the FinCEN website for updates on CTA compliance.