Late last night, the Fifth Circuit Court, through a merits panel evaluating the parties’ claims, vacated the motion to stay the injunction. This decision means that FinCEN no longer has the authority to enforce BOI reporting requirements at this time. We have reached out to FinCEN for clarification, but as of now, they have not updated their website or confirmed whether filing is voluntary again or if further delays to filings beyond January 13, 2025, will be provided. We continue to advocate strongly for additional delays. Guidance for Members: We are advising those assisting clients with BOI filings to: • Continue gathering the required information from clients. • Be prepared to file BOI reports if the injunction is lifted again. For more details, you can review the court’s decision here: Fifth Circuit Opinion |