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Status of CTA Rapidly Changes (Again). BOI Filing Not Currently Required.

December 27th, 2024

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Shortly before 4:00 p.m. ET on December 27th, FinCEN issued an alert, stating that businesses are not currently required to file a Beneficial Ownership Information (BOI) report.

What Happened:

  • As stated in Lipsitz Green Scime Cambria’s earlier alert, on December 23, 2024, the U.S. Court of Appeals for the Fifth Circuit, issued a ruling which reinstated requirements and obligations for business owners under the Corporate Transparency Act (CTA).
  • On December 26, 2024, the merits panel of the Fifth Circuit of the U.S. Court of Appeals, issued an order, vacating the Court’s December 23rd decision.
  • The U.S. Court of Appeals’ December 26th ruling, reinstates a nationwide preliminary injunction on enforcing the CTA, which was initially issued by a U.S. District Court on December 3rd.
  • Due to the December 26th Court ruling, FinCEN has announced that businesses are not currently required to file a BOI report and are not subject to liability if they fail to do so.


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Enforcement of CTA Reinstated. BOI Filing Deadline Now January 13th.

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The U.S. Court of Appeals has reinstated the enforcement of the Corporate Transparency Act (CTA).

What Happened:

  • As detailed in Lipsitz Green Scime Cambria’s previous alert, on December 3, 2024, a U.S. District Court Judge in Texas, imposed a nationwide preliminary injunction on the enforcement of the CTA.
  • The U.S. Department of Justice filed on appeal of the December 3rd decision.
  • On December 23, 2024, the U.S. Court of Appeals for the Fifth Circuit, issued a ruling, which lifted the preliminary injunction on the enforcement of the CTA.
  • FinCEN has announced that due to the various court rulings, the BOI filing deadline that had been set for January 1, 2025, has been extended to January 13, 2025.


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New York State Issues Guidance for 2025’s Paid Prenatal Leave Law

December 17th, 2024
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Effective January 1, 2025, employers in New York State will be mandated to comply with the Paid Prenatal Leave Law. This law will give covered employees, which includes pregnant employees as well as employees receiving fertility and in-vitro services, the ability to take paid leave for any pregnancy-related medical appointment.

The goal of Paid Prenatal Leave is to ensure covered employees receive health care needed to address all pregnancy related care, to create healthy outcomes without jeopardizing their employment or finances. This is the first policy of its kind in the United States.

Paid Prenatal Leave was included in New York State’s 2025 budget, as amendment to New York State’s existing Paid Sick Leave Law (Section 196-b of New York Labor Law). The budget was signed by Governor Kathy Hochul on April 10, 2024.

With the January 1, 2025 implementation date fast approaching, New York State recently released formal guidance on specific requirements and enforcement of the Paid Prenatal Leave Law.
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