Corporate Transparency Act (“CTA”)
About Our CTA Service
The CTA creates a new reporting requirement under which Reporting Companies, which includes community associations, must file a Beneficial Ownership Information (“BOI”) report with the Financial Crimes Enforcement Network (“FinCEN”). Altitude will act as a third-party service provider in filing BOI reports for associations. Download our information sheet below for details on our new CTA service!
Download the CTA Information Sheet
If you are interested in Altitude Community Law filing your CTA BOI report, please fill out the form below and we will send you the fee agreement along with instructions for the information we will need.
LATEST CTA DEVELOPMENT:
As stated in our most recent eblast, on December 23rd a panel of the Fifth Circuit Court of Appeals granted a motion to lift the injunction on CTA reporting requirements. This served to reinstate the January 1, 2025 deadline for associations to file their Beneficial Ownership Information (“BOI”) reports with the Financial Crimes Enforcement Network (“FinCEN”). Immediately after, FinCEN provided an extension to January 13, 2025 to file such reports.
Three days later, on December 26th a different panel of the Court entered an Order restoring the injunction. This Order means that the CTA reporting requirements are again suspended, and FinCEN has posted on its website that compliance is again voluntary.
Additionally, on December 31st the Department of Justice sought a stay of the injunction pending the ongoing appeal from the Supreme Court of the United States.
So now we await two court’s decisions: The Supreme Court’s decision regarding the December 31st request for stay, and the Court of Appeals decision on the underlying merits of the case (i.e., the CTA’s constitutionality).
The Supreme Court has set a January 10 deadline for the plaintiff in the Texas Top Cop Shop case to address the Department of Justice’s motion for a stay. Accordingly, the Supreme Court is actively considering whether to lift the preliminary injunction.
The Court of Appeals has set March 25, 2025 as the date for oral argument on the merits. After the briefing is completed and arguments are considered, the Court of Appeals will report its decision.
As we have all seen over the past month, CTA news shifts rapidly and unexpectedly. Although filing is currently voluntary, it is still our strong recommendation that boards gather information to be ready to file, or simply voluntarily comply. We will continue to provide you updates.