Preliminary Injunction Temporarily Blocks Enforcement of the Corporate Transparency Act Nationwide

On December 3, 2024, the U.S. District Court for the Eastern District of Texas issued a preliminary injunction, temporarily blocking enforcement of the Corporate Transparency Act (“CTA”) and its reporting rule on a nationwide basis.[1] For the time being, the preliminary injunction means reporting companies are not required to comply with the CTA’s reporting requirements…

Federal Trade Commission Adopts New “Click-to-Cancel” Rule

Written by: Ian M. Stanford and Steven T. Lawrence If your business includes any sort of subscription-based or membership model, a new federal regulation may change how your customers cancel their subscription or membership.  On October 16, 2024, the Federal Trade Commission announced its final “Click-to-Cancel” rule.  The new rule applies to “negative option programs,”…

The Corporate Transparency Act: July and September 2024 Update to the Beneficial Ownership Information Frequently Asked Questions

In July and September 2024, FinCEN provided some additional guidance on the Corporate Transparency Act (“CTA”) by updating its Frequently Asked Questions web page related to beneficial ownership information report filing obligations of terminated, administratively dissolved and disregarded entities, and clarifying the contents of such beneficial ownership information report filings.  Below is a brief summary…

The Corporate Transparency Act – A Series of the Latest Updates for Reporting Companies

The effective date of the Corporate Transparency Act and its corresponding rules promulgated by FinCEN was January 1, 2024.  In January 2023, we published an article that discussed the intent and importance of the CTA (available here).  The CTA may be a landmark piece of legislation that reshapes how certain entities report and disclose information…