What Happened?
- This past Friday evening (March 21, 2025), the Financial Crimes Enforcement Network (FinCEN) issued an interim final rule, which removes the requirement for U.S. companies and U.S. persons to report beneficial ownership information (BOI) under the Corporate Transparency Act (CTA).
Court Ruling Reinstates Enforcement of the CTA
February 24th, 2025
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FinCEN has announced that reporting requirements for the Corporate Transparency Act are back in effect.
What Happened:
- As reported in an earlier alert issued by Lipsitz Green Scime Cambria, on December 26, 2024, the U.S. Court of Appeals for the Fifth Circuit reinstated a nationwide preliminary injunction on the enforcement of the CTA.
- The preliminary injunction was initially ordered by the U.S. District Court for the Eastern District of Texas on December 2. 2024, in a lawsuit that challenged the constitutionality of the CTA, Texas Top Cop Shop, Inc., et al. v. Merrit Garland, Attorney General of the United States, et al.
- On January 7, 2025, the U.S. District Court for the Eastern District of Texas, issued an order in another lawsuit challenging the CTA, Smith, et al. v. U.S. Department of Treasury, et al. The January 7th ruling also ordered a stay on FinCEN’s enforcement of the CTA.
- On February 5, 2025, the U.S. Department of Justice filed an appeal of the January 7th ruling and asked that the stay on the enforcement of the CTA be lifted during the appeals process.
- On February 18, 2025, the U.S. District Court for the Eastern District of Texas granted the U.S. Department of Justice’s request and lifted the stay on the enforcement of the CTA.
- This ruling from February 18, 2025 gives FinCEN the authority to enforce the reporting obligations business owners have under the CTA.
Next Real Estate Roundtable January 23rd | How to Address Emotional Support Animal Requests
January 8th, 2025
Our next in-person Real Estate Roundtable will take place on Thursday, January 23rd at 9:00 AM at The Buffalo Club. The event will be held in the Roosevelt Room, which is located on the 2nd floor of The Buffalo Club.
Click “RSVP” below if you would like to attend the January 23rd Real Estate Roundtable, which is free of charge.
At our next Real Estate Roundtable, Jaime Michelle Cain will discuss matters related to Emotional Support Animal requests. Topics that will be reviewed include:
- What HUD Guidance Advises
- How to Process and Respond to Requests
- How to Engage in the Interactive Process with Tenants
- How to Address Multiple Animal Request