IMPORTANT UPDATE - ENFORCEMENT OF CTA ENJOINED BY US DISTRICT COURT
Updated: January 10, 2025
In light of a recent federal court order, reporting companies are not currently required to file beneficial ownership information with FinCEN and are not subject to liability if they fail to do so while the order remains in force. However, reporting companies may continue to voluntarily submit beneficial ownership information reports.
Summary of Recent Events:
On December 3, 2024, in the matter of Texas Top Cop Shop, Inc., et al. v. Garland, et al., Case No. 4:24-cv-478 (E.D. Tex.), a federal judge from the US District Court for the Eastern District of Texas issued a sweeping order prohibiting the federal government from enforcing the CTA anywhere in the country.
The Department of the Treasury appealed this ruling, and on December 23, 2024, the US Court of Appeals of the Fifth District granted a stay of the District Court’s preliminary injunction, pending the outcome of the Department of the Treasury’s appeal. However, on December 26, 2024, a “merits panel” of the US Court of Appeals of the Fifth District reevaluated the earlier December 23, 2024 decision of the US Court of Appeals and reinstated the stay of the nationwide preliminary injunction on the CTA that had been removed on December 23, 2024.
The US Supreme Court has now been asked by the Department of the Treasury to remove the nationwide injunction while this matter proceeds through the appellate process. A decision by the US Supreme Court has not yet been made.
This notice is provided as a courtesy and is not intended to, nor shall it constitute, legal advice. Teeple Hall, LLP is not obligated to provide additional updates.
Teeple Hall, LLP
CTA Portal
Your Single Solution for Attorney Client Protected FINCen1 Beneficial Owner Compliance!
With a history and focus on government reporting and compliance matters, as well as decades of experience in
tax reporting and compliance, Teeple Hall, LLP is well-positioned to guide Reporting Companies2 through the
complexities of the Corporate Transparency Act (CTA).
For Reporting Companies with simple ownership and management structures, we have developed proprietary
software, the Teeple Hall, LLP CTA Portal, allowing Clients to collect, categorize, submit BOI3 Reports, and maintain audit trails of a Reporting Company’s FinCEN compliance for a modest annual fee.
The Teeple Hall, LLP CTA Portal features provide a secure and managed approach to FinCEN CTA BOI
Reporting under Attorney-Client Privilege, with features as follows:
Provision of 24/7 online access to a customized CTA Portal for each Client/Reporting Company;
Paralegal and/or Attorney review of beneficial ownership documentation submitted into the CTA Portal
by the Reporting Company to validate BOI for conformance with FinCEN submission requirements;
Compilation of BOI data uploaded to the customized CTA Portal into BOI Reports (initial report and
updated reports) for Client/Reporting Company review and secure submission to FinCEN via the CTA
Portal;
Access to Paralegal and/or Attorney staff to answer questions related to CTA definitions and CTA Portal
customer service; and
Maintenance of BOI data and documentation in one web-based, secure location for ease of
management and reference as a FinCEN CTA compliance audit trail.
The Teeple Hall, LLP CTA Portal functionalities have been tailored and developed to assist Clients/
Reporting Companies to navigate the complexities of BOI reporting and the requirements of the CTA,
with functionalities as follows:
Notice of latest CTA news, updates, and revised legislation published by FinCEN via CTA Portal alerts and
automated emails;
Notice of pending expiration dates of BOI identification documents uploaded to the CTA Portal;
Secure upload and storage of Beneficial Owner4 identifying documentation to CTA Portal; and
Secure submission of BOI Reports to FinCEN via the CTA Portal.
The CTA Portal is provided to Clients for an annual fee of $250.00 and includes unlimited BOI Report
submissions to FinCEN during the annual Term5.
Click here to start the engagement process and create your customized CTA Portal page
For more information on Teeple Hall, LLP’s broader range of CTA compliance and reporting
solutions, as well as general information on the Corporate Transparency Act, please click
here.
______________________ 1 “FinCEN” means the Financial Crimes Enforcement Network, a bureau of the United States Department of the
Treasury. 2 Defined in 31 CFR 1010.380(c). 3 Defined in 31 CFR 1010.380(b). 4 Defined in 31 CFR 1010.380(d). 5 “Term” shall have the meaning ascribed to it in the Fee Agreement signed by the Client to commence CTA Portal
services
