On the evening of December 26, 2024, the 5th Circuit Court of Appeals issued a significant decision in Texas Top Cop v. Garland. The court vacated its prior ruling that had granted the United States’ Motion for a Temporary Stay pending appeal on the enforcement of the Corporate Transparency Act (CTA). This latest development means that, for now, the Financial Crimes Enforcement Network (FinCEN) within the U.S. Department of Treasury is once again prohibited from enforcing the CTA’s disclosure requirements against “Reporting Companies” while the appeal remains unresolved.
This ongoing legal back-and-forth demonstrates the unpredictable enforcement status of the CTA. For associations, businesses, and other reporting entities, it’s crucial to stay informed to ensure compliance if and when the requirements are reinstated. Consulting a knowledgeable real estate attorney in Orlando or an HOA lawyer can help clarify obligations and keep your organization prepared.
For many entities, the deadline to comply with the CTA’s reporting obligations was already approaching. However, some organizations in Florida may benefit from a six-month extension due to the impact of this year’s hurricanes. Eligible counties include:
Alachua, Baker, Bradford, Brevard, Broward, Charlotte, Citrus, Collier, Columbia, DeSoto, Dixie, Duval, Flagler, Gilchrist, Glades, Hamilton, Hardee, Hendry, Hernando, Highlands, Hillsborough, Indian River, Lafayette, Lake, Lee, Levy, Madison, Manatee, Marion, Miami-Dade, Monroe, Okeechobee, Orange, Osceola, Palm Beach, Pasco, Pinellas, Polk, Putnam, Sarasota, Seminole, St. Johns, St. Lucie, Sumter, Suwannee, Taylor, Union, and Volusia.
Organizations in these areas should evaluate their eligibility and take advantage of this extension if necessary. A real estate lawyer near you can provide guidance on whether your community qualifies and how to proceed.
