Yesterday, we reported that the motions panel of the Federal Court of Appeals for the 5th Circuit decided, pending appeal, that reporting companies are required to file their beneficial ownership information with FinCEN no later than January 13, 2025. However, late yesterday, the merits panel of the same Court ordered a portion of the motions panel decision to be vacated, effectively reinstating the District Court’s December 3, 2024 preliminary injunction staying the enforcement of the Corporate Transparency Act (CTA) and its Reporting Rule.

Earlier this month, we reported that the U.S. District Court for the Eastern District of Texas issued a preliminary injunction staying the enforcement of the Corporate Transparency Act (CTA) and its Reporting Rule. This week the Federal Court of Appeals for the 5th Circuit decided that reporting companies are required to file their beneficial ownership information with FinCEN.