As of December 4, 2024, the U.S. District Court for the Eastern District of Texas (the “Court”) has issued a nationwide preliminary injunction preventing the federal government from enforcing the beneficial ownership reporting requirements imposed by the Corporate Transparency Act (the “CTA”).
The CTA, which became effective on January 1, 2024, imposes obligations on millions of entities (each, a “Reporting Company”), including private fund advisers and the private funds they advise (subject to certain exemptions), to continuously report certain “beneficial ownership information” (such information, “BOI”, and the reports containing the BOI, the “Reports”) with FinCEN, which has passed the Beneficial Ownership Information Reporting Rule (the “Reporting Rule”) in order to implement the CTA.
The Court’s order states that neither the CTA nor the Reporting Rule may be enforced and that Reporting Companies need not comply with the CTA’s upcoming January 1, 2025 deadline for filing Reports.
Key Takeaway: Private funds (and their advisers) currently do not need to file Reports to comply with their obligations under the CTA.
Riveles Wahab LLP (“RW”) will continue to monitor developments related to the CTA and the Reporting Rule. If you have questions regarding these updates or the CTA’s requirements, please contact us at admin@randwlawfirm.com.
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