COMPLIANCE ALERT SECOND UPDATE: CORPORATE TRANSPARENCY ACT INJUNCTION STAYED

NSSF^® is sending this second update to keep members informed on the status of their reporting obligations under the Corporate Transparency Act (“CTA”).

On December 23, 2024, the Fifth Circuit Court of Appeals granted a stay of the nationwide injunction against the CTA on which we had previously reported. This means that companies will still be required to file beneficial ownership reports as required by the CTA, pending a full appeal of the challenge.

The original reporting deadline for most companies was January 1, 2025. However, FinCEN has chosen to extend the reporting deadlines, giving most companies an additional two weeks to file. Companies which were formed prior to January 1, 2024, now have until January 13, 2025, to file. Companies formed within the last year have also received deadline extensions, the full details of which can be found here.

NSSF previously alerted members to the CTA and its reporting requirements, which require the vast majority of companies to report certain beneficial ownership information to the US Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”). That original alert, with additional information on the CTA and the reporting requirements, can be found here. The vast majority of Americans have been unaware of these requirements, and the consequences for non-compliance, which can include felony-level penalties that automatically prohibit violators from purchasing or possessing firearms and exercising their Second Amendment rights.

NSSF will continue to monitor developments in relation to the CTA and the challenges against it, and keep members informed of any important status changes.