Last night, December 26, 2024, the US Court of Appeals for the 5th Circuit vacated the order entered on December 23, 2024 that reinstated the filing requirements under the federal Corporate Transparency Act (“CTA”). This is the same court order that was the focus of our December 24, 2024 client alert to you, which highlighted that a new filing deadline of January 13, 2025 had been announced by FinCEN, the department that enforces CTA.
Based upon the court order that was entered last night, the December 26, 2024 order, the nationwide stay of the CTA is back in effect until the 5thCircuit Court of Appeals can convene again for a full panel hearing on the validity of the CTA.
This means that the January 13, 2025 filing deadline that we communicated to you in our last alert on December 24, 2024 has been rescinded.
We have heard from several of you in recent days that with the roller coaster of court orders involving CTA that your community association is eager to proceed to complete or restart its CTA filing. Rees Broome, PC remains available to assist clients with the reporting process in a voluntary rather than mandatory manner. If you did not get a confirmation of completed filing from our office already, this means your association does not have a completed CTA filing. Our office is stopping all filing work, unless expressly requested to proceed with a particular filing.
We appreciate that the timing of these notices is less than ideal as you enjoy your holiday celebrations. However, we wanted to make sure our clients had the latest information and we wanted to highlight that CTA filings are again voluntary.