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Corporate Transparency Act to be Re-evaluated

Client Alert

Over the past several months, the federal judiciary has provided numerous rulings on the enforceability of the Corporate Transparency Act (“CTA”), which became effective January 1, 2024.  For a more detailed overview on the CTA, click here.

On February 20th, we alerted business owners that the reporting required by the CTA was reinstated, as all nationwide federal injunctions had been lifted. However, on February 27th, the Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a press release providing that no enforcement actions will be taken against businesses that fail to submit reporting.

The press release provides that FinCEN will be reevaluating the CTA and will provide new guidance and clarity “as quickly as possible.”  Public comment will be solicited by FinCEN during this reevaluation.

Given FinCEN’s new position on the CTA, businesses no longer have any obligation to submit reporting.  A reevaluation of reporting obligations will also be warranted by business owners in the event FinCEN does publish a new final reporting rule, as the impetus for change was a reduction of the regulatory burden on businesses while prioritizing reporting only for those entities that pose the most significant risks.

For further guidance on the changing landscape of CTA reporting, business owners should reach out to their BMD legal advisors or contact BMD Member Blake Gerney at brgerney@bmdllc.com.


Telemedicine Flexibilities Extended to March 31, 2025

The American Relief Act of 2025 extends key telehealth flexibilities through March 31, 2025, originally enacted during the COVID-19 Public Health Emergency (PHE). These flexibilities remove geographic and originating site restrictions for Medicare patients, expand the list of qualified practitioners, and allow for audio-only services and telehealth mental health care without in-person requirements. Although this extension is temporary, it provides continued access to essential healthcare services. Congress will need to pass permanent legislation to solidify these changes beyond March 2025.

Corporate Transparency Act Is Back in Effect: Are You Ready?

On December 23, 2024, the Fifth Circuit Court of Appeals reinstated the filing requirements under the Corporate Transparency Act (CTA), overturning a prior injunction. Businesses now have updated deadlines to file initial beneficial ownership information reports with the Financial Crimes Enforcement Network (FinCEN), based on their registration date. Affected companies must comply with these new deadlines, which vary depending on when the company was created or registered.

Checklist of Legal Considerations for a Med Spa

Checklist of key legal considerations for a med spa providing a broad overview of certain state and federal legal requirements.

Understanding Ohio House Bill 660: A Game-Changer for Student-Athletes

Ohio House Bill 660 is set to reshape Name, Image, and Likeness (NIL) agreements for student-athletes by allowing direct compensation from universities and providing greater financial opportunities while preserving amateur status. The bill simplifies the regulatory framework, introduces safeguards, and creates challenges and ethical considerations for stakeholders.

Effective December 12, 2024: Key Updates to Ohio Medicaid Rules for CPC and CMC Programs

Ohio Medicaid has amended rules for the Comprehensive Primary Care (CPC) and Comprehensive Maternal Care (CMC) programs, effective December 12, 2024. Key updates include expanded provider eligibility, stricter cultural competency training timelines, new clinical quality metrics, and changes to maternal care requirements.