On January 23, 2025, the Supreme Court granted the government’s motion to stay a nationwide injunction issued by a federal judge in Texas (Texas Top Cop Shop, Inc. v. McHenry—formerly, Texas Top Cop Shop v. Garland).  Translation: The Court lifted the injunction prohibiting enforcement of the Corporate Transparency Act.

HOWEVER, because a separate nationwide order issued by a different federal trial court judge in Texas (Smith v. U.S. Department of the Treasury) still remains in place, reporting companies are not currently required to file BOI reports with FinCEN despite the Supreme Court’s action in Texas Top Cop Shop.

Reporting companies also are not subject to liability if they fail to file this information while the Smith order remains in force. However, reporting companies may continue to voluntarily submit beneficial ownership information reports.