Tl;dr*: File your CTA beneficial owner registration by March 21, 2025. Probably.
The CTA has been the subject of various federal lawsuits and as a result, various conflicting rulings. We have focused primarily on the Texas Top Cop Shop cases, but other cases have also resulted in local and nationwide injunctions against the CTA. The United States Supreme Court had stayed the injunction in Texas Top Cop Shop, but a nationwide injunction remained in place due to a January ruling in Samantha Smith and Robert Means v. U.S. Department of the Treasury, No. 6:24-CV-336 (E.D. Texas 1/7/25).
That injunction has now also been lifted, which means that – as of right now, BOI reporting requirements are legal, and FinCEN has issued a 30-day filing delay making your filing due date March 21. FinCEN has also stated that it “will assess its options to modify further deadlines or reporting requirements for lower-risk entities, including many U.S. small businesses, while prioritizing reporting for those entities that pose the most significant national security risks.”
We believe that our community association clients are lower-risk entities, as they are typically non-profit corporations with simple governance structures and transparent financial recordkeeping obligations. (I’m sure some people believe HOAs are among the country’s most significant national security risks, but I digress.)
In addition, on February 10, 2025, the U.S. House of Representatives voted unanimously in favor of pushing the BOI reporting deadline out to 2026. See, the country can come together!!!
Reach out to any WLPP attorney for the latest news on CTA obligations, and come back here for more tired jokes about state and federal legislation!
*tl:dr means “too long, didn’t read!”