December 4, 2024 – On December 3, 2024, in the case Texas Top Cop Shop, Inc. et al. vs. Garland, the U.S. District Court for the Eastern District of Texas issued a nationwide preliminary injunction against enforcement of the Corporate Transparency Act (“CTA”). Unlike prior cases challenging the CTA, the Court did not limit its ruling to the plaintiffs in the case, finding that the injunction should apply nationwide to all existing reporting companies.

This nationwide injunction applies against enforcement of the CTA and the impending January 1, 2025 filing deadline (if not sooner for those reporting companies subject to a 90 day from formation deadline). The court stated “[T]he CTA, 31 U.S.C. § 5336 is hereby enjoined. Enforcement of the Reporting Rule, 31 C.F.R. 1010.380 is also hereby enjoined, and the compliance deadline is stayed under § 705 of the APA. Neither may be enforced, and reporting companies need not comply with the CTA’s January 1, 2025, BOI reporting deadline pending further order of the Court.”

CAUTION – this is only a preliminary injunction, and we expect comment or further action from the U.S. Department of the Treasury, as enforcement could resume if the Court’s order is overturned. It is important for reporting companies to stay alert for additional updates and proceedings that could modify or change this order.

RRD will continue monitoring developments, and in the meantime please contact your RRD attorney with any questions about the injunction or the CTA in general.