On December 23, 2024, a three-judge panel of the United States Court of Appeals for the Fifth Circuit revived the enforceability of the Corporate Transparency Act (“CTA”). A federal district court in Texas previously issued a nationwide preliminary injunction preventing the federal government from enforcing the CTA.
What does this mean for health care entities?
Following the decision, reporting companies must comply with the extended reporting deadlines imposed by the Financial Crimes Enforcement Network (“FinCEN”):
- Reporting companies created or registered before January 1, 2024, have until January 13, 2025, to file their initial beneficial ownership information reports with FinCEN.
- Reporting companies created or registered in the United States after September 4, 2024, with a filing deadline between December 3, 2024, and December 23, 2024, have until January 13, 2025, to file their initial beneficial ownership information reports with FinCEN.
- Reporting companies created or registered in the United States on or after December 3, 2024, and on or before December 23, 2024, have an additional 21 days from their original filing deadline to file their initial beneficial ownership information reports with FinCEN.
- Reporting companies created or registered in the United States on or after January 1, 2025, have 30 days to file their initial beneficial ownership information reports with FinCEN after receiving actual or public notice that their creation or registration is effective.
You can find more information on the CTA, including who is impacted, the reporting requirements, applicable exemptions and general compliance considerations here.
As this matter progresses, Hall Render will continue to monitor the situation and the reporting obligations for health care entities. If you have any questions about this topic or would like additional information, please contact:
- John Bowen at jbowen@hallrender.com or (317) 429-3629; or
- Eric Speer at espeer@hallrender.com or (317) 741-0661;
- Your primary Hall Render contact.
Hall Render blog posts and articles are intended for informational purposes only. For ethical reasons, Hall Render attorneys cannot—outside of an attorney-client relationship—answer specific questions that would be legal advice.
