FinCEN Corporate Transparency Act filings shut down by the US District Court for the Eastern District of Texas
Under the Corporate Transparency Act (CTA), entities that were in existence before January 1, 2024 are required to file Beneficial Owner Reports (BOR) with the Financial Crimes Enforcement Network (FinCEN) before January 1, 2025. Requirements also exist that set forth the time frame for filing the report when a new entity is formed. On December 3, 2024, an injunction was issued by a federal court that applies nationwide. Under the injunction, no company may be held liable for failing to file a BOR. The federal government has appealed, and we are following all developments very closely. If you navigate to the FinCEN site, you will find the following:
BOI e-Filing Alert: Please note that beneficial ownership information reporting requirements have been affected by a recent federal court order. The Department of the Treasury is appealing that order. In the meantime, reporting companies are not currently required to file a BOIR and are not subject to liability if they fail to do so while the applicable order remains in force.
However, reporting companies may still opt to file a BOIR.
The net result is that FOR NOW, entities are not required to file BORs and will not be penalized for failing to file while the injunction is in effect. If the government is successful, new filing date requirements will be put into effect. If the district court ruling stands and survives future challenges, the CTA FinCEN filing requirements never get resurrected. Watch for future updates.
New Mandatory Timelines for Review of Cooperative Purchase Applications
On January 29, 2026, the New York City Council enacted Local Law 58 of 2026, adding a new chapter to the New York City Administrative Code that imposes statutory deadlines on cooperative boards when reviewing purchase applications that require board approval. The law addresses longstanding concerns about protracted and unpredictable co-op approval timelines and will […]
New Jersey Appellate Division Affirms NJDEP Environmental Justice Rules – What Regulated Entities Need to Know
On January 5, 2026, the New Jersey Appellate Division issued a published decision in In the Matter of the Adoption of N.J.A.C. 7:1C, rejecting consolidated challenges filed by industry and labor petitioners to the New Jersey Department of Environmental Protection’s Environmental Justice Rules. The decision affirms NJDEP’s authority to implement New Jersey’s 2020 Environmental Justice […]
EEOC Enforcement Priorities Take Shape Under New General Counsel Leadership
On November 18, 2025, President Trump nominated M. Carter Crow, the Global Head of Labor and Employment at Norton Rose Fulbright LLP, to be General Counsel of the EEOC. Carter Crow focuses his practice on wage and hour litigation, contracts, and restrictive covenants. As of this writing, Carter Crow has yet to be voted out […]
President Trump’s Nomination of Brittany Bull Panuccio Restores EEOC Quorum
What the Commission’s New Majority Means for Workplace Enforcement and Employer Compliance On October 7, 2025, the U.S. Senate confirmed President Trump’s nomination of Brittany Bull Panuccio to a vacant seat on the Equal Employment Opportunity Commission (EEOC or the Commission). Commissioner Panuccio’s confirmation grants EEOC a quorum for the first time since President Trump’s […]
The Intersection of SEQRA Reform and New York’s Updated Building and Energy Codes: Impacts on Project Planning
As discussed in prior updates, Governor Hochul’s administration has proposed targeted adjustments to the State Environmental Quality Review Act (SEQRA) to reduce procedural delay for certain housing projects that do not present significant environmental impacts. These proposals are part of the Governor’s 2026 agenda and include targeted SEQRA exemptions, geographic eligibility limits, floodplain exclusions, and […]
Proposed SEQRA Updates Aim to Accelerate Housing While Maintaining Environmental Standards
New York State is pursuing a significant reform initiative aimed at reducing procedural delays associated with the State Environmental Quality Review Act (SEQRA) for certain housing projects. The proposal, which is part of Governor Kathy Hochul’s 2026 State of the State agenda under the “Let Them Build” initiative, seeks to create targeted exemptions from SEQRA […]
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