To Our Clients and Friends:
On December 26, 2024, a different panel of the U.S. Court of Appeals for the Fifth Circuit issued an order vacating the Court’s December 23, 2024 order, which granted a stay of the preliminary injunction. Accordingly, as of December 26, 2024, reporting companies are not currently required to file beneficial ownership information (“BOI”) reports.

This case is still being litigated. Accordingly, legal developments could occur quickly or without warning, so we recommend reporting companies proceed carefully and be prepared to file a report by the required deadline if the preliminary injunction is stayed (again) or overturned on appeal.

If you have any questions about CTA compliance in light of this update, please contact the GCT attorney with whom you work. GCT will continue to monitor developments and provide updates as they become
available.