The legal battles surrounding the Corporate Transparency Act (CTA) continue as the District Court for the Eastern District of Texas has lifted an injunction that previously halted its enforcement. This decision, issued in Smith, et al. v. U.S. Department of the Treasury, et al. (E.D. Tex., Feb. 17, 2025, Case No. 6:24-cv-00336), reinstates the CTA’s reporting requirements—at least for now.
Background: Supreme Court Reversal
This development follows the U.S. Supreme Court’s ruling in McHenry v. Texas Top Cop Shop, Inc., which overturned a 5th Circuit decision that had upheld a nationwide injunction against the CTA’s enforcement. The Supreme Court’s order in McHenry effectively reversed the lower court’s ruling, restoring the CTA’s beneficial ownership reporting requirements. (2025 WL 272062 at 1; see also Texas Top Cop Shop, Inc. v. Garland, E.D. Tex., Dec. 5, 2024, Case No. 4:24-cv-00478-ALM).
FinCEN Extends Reporting Deadline
In response to the court’s decision, the Financial Crimes Enforcement Network (FinCEN) has issued a notice granting affected businesses additional time to comply. According to the notice:
“[B]ecause the Department of the Treasury…recognizes that reporting companies may need additional time to comply with their BOI reporting obligations, FinCEN is generally extending the deadline 30 calendar days from February 19, 2025, for most companies.” (FinCEN Notice FIN-2025-CTA1, Feb. 18, 2025).
New Filing Deadline for HOAs and Other Reporting Entities
As a result, homeowners’ associations (HOAs) and other reporting companies must submit their initial Beneficial Ownership Information (BOI) report to FinCEN no later than March 21, 2025.
With the CTA’s reporting requirements now back in effect, affected entities should ensure compliance to avoid potential penalties. However, given the ongoing legal challenges, further changes could still arise.