On December 26, 2024, in a very short opinion, the U.S. Court of Appeals for the Fifth Circuit, which on December 23 had lifted a national stay imposed by the U.S. District Court for the Eastern District of Texas in the case of Texas Top Cop Shop, Inc., et al. v. Garland, et al., No. 4:24-cv-00478 (E.D. Tex.), prohibiting the federal government from enforcing the Corporate Transparency Act (“CTA”), reinstated that national stay. In its opinion, the Court of Appeals indicated that it would soon issue a decision on the substance of the case.

In light of the foregoing, the CTA is not enforceable and new and existing reporting companies otherwise subject to the CTA are not required to report beneficial ownership information. We will keep you apprised of any further developments in this fast-moving case.