The nationwide injunction of the U.S. District Court was reinstated by the merits panel of the Fifth Circuit Court of Appeals late on December 26, 2024 and can be seen at https://www.ca5.uscourts.gov/opinions/unpub/24/24-40792.pdf.
This decision overturns the previous opinion of a motions panel of the Fifth Circuit Court of Appeals on December 23.
The December 26 decision by the merits panel means that Reporting Companies under the Corporate Transparency Act do not have to file the requested information with FinCEN and the enforcement of the January 1, 2025, deadline for existing entities, 90-day deadline for entities created in 2024 and 30-day deadline for entities created in 2025 remains stayed.
The merits panel order is in place while the expediated appeal of the underlying District Court opinion is pending. Affected entities should continue to remain in contact with their counsel as the case is not yet final and appeals remain.