Yes, the preliminary injunction on the enforcement of the CTA is back, and no, you are not imagining things. This means you are not required to file FinCEN BOIR at this time.
Here’s a brief timeline of recent CTA developments:
- Dec. 3, 2024: A Texas federal court issued a nationwide preliminary injunction on CTA enforcement (Texas Top COP Shop, Inc. v. Merrick Garland).
- Dec. 23, 2024: The Fifth Circuit granted the DOJ’s motion for a stay on the injunction, and FinCEN extended the compliance deadline from Jan. 1 to Jan. 13, 2025.
- Dec. 26, 2024: The Fifth Circuit vacated the stay, reinstating the injunction. FinCEN BOIR requirements are paused until the constitutional oral arguments on the CTA in March 2025.
Our legal team is closely monitoring the situation.
Key Points to Know:
- Filing Not Required for Now: The preliminary injunction means FinCEN BOIR filing isn’t required unless the injunction is removed or lifted after the March 2025 oral argument. However, it’s crucial to be prepared.
- CTA Is Not Dead: This is only a temporary pause. The oral argument on March 2025 may reinstate FinCEN reporting requirements.
- Prepare for Filing: If the enforcement of CTA is reinstated, you may need to comply immediately after the oral argument.
- Don’t overspend on filing now—ensure you’re ready to file as soon as FinCEN BOIR is required. Choose a solution that allows you to prepare filings with minimal or no upfront charges, only charging the full price if and when you file. Avoid services pushing unnecessary filings without disclosing that FinCEN BOIR isn’t currently mandatory. Stay prepared to act quickly without wasting money!
Our Recommendation – Get Prepared Now
We strongly advise completing your preparation on SeedJura.CO before March 2025- Enter your entities’ information now to ensure you’re ready for any outcome.
Prepare for filing for only $10 with SeedJura.CO:
Organize all your entities on SeedJura.CO for a one-time $10 sign-up fee, regardless of the number of entities, including automatic legal BOI analysis to identify beneficial owners and finalize information in a “ready-to-file” status.
With SeedJura.CO, you have complete control over when to file with FinCEN—just a click of a button. Once the preparation on SeedJura.CO is complete, you have the following options:
- Option 1 – Voluntarily File now. You can choose to voluntarily file with FinCEN while the preliminary injunction remains in effect.
- Option 2 – File only if the preliminary injunction is removed in the future. You can choose to file only if and after the injunction is lifted.
SeedJura’s FinCEN BOIR service fee is only required if and when you click on “Confirm to File”
You only pay when you click the "Confirm to File" button on SeedJura.CO (timing based on which option you choose above):
$89.99 per entity
FREE for the 1st entity
$100 membership fee per year (no matter how many entities you have)
Unlimited updates and refiling (per year)
E.g., if you have 5 entities, it will be $459.96 (i.e., $89.99 x 4 + $100)
REFUND - File with confidence and Get Organized.
If the CTA is canceled by the U.S. Supreme Court or Federal Government, SeedJura will refund your FinCEN BOIR service fees for already filed entities (minus any applicable third-party fees, such as PayPal).
Your entities will remain organized on SeedJura.CO, and you’ll receive notifications about any future filing requirements (e.g., state-level filings). SeedJura.CO will assist you with any new filings, ensuring compliance, and will also offer new features like automatic legal document generation for your entities, all at affordable fees.
Avoid last-minute chaos by preparing in advance. Filing takes time, especially for multiple entities. Start now to ensure compliance.
You can sign up for SeedJura.CO today by scanning QR Code below or go to www.seedjura.com
SeedJura.CO - an entity management tech solution offered by our law firm, SeedJura, PLLC. Our lawyers are here to support you every step of the way.
