On February 27, 2025, FinCEN announced that it will not issue any fines or penalties or take any enforcement actions against companies for the failure to file or update beneficial ownership information (“BOI”) reports pursuant to the Corporate Transparency Act (the “CTA”) until the United States Department of the Treasury provides new guidance.
As we have covered in prior Client Alerts, over the past few months there have been numerous developments in connection with various pending cases challenging the constitutionality of the Corporate Transparency Act (the “CTA”).
Recently the New York State Legislature passed the Good Cause Eviction Law requiring landlords to have a statutorily specified reason to evict a tenant. A landlord will no longer be able to evict a month-to-month tenant by giving the requisite notice. Nor will a landlord be able to evict a tenant at the end of the tenant’s lease unless the landlord has grounds to evict the tenant as specified by the Good Cause Eviction Law. The Good Cause Eviction Law is an “opt-in” law meaning that a municipality must adopt it by local law for the new law to be enforced.
On January 23, 2025, the United States Supreme Court issued a stay of the preliminary injunction enjoining enforcement of the Corporate Transparency Act (the “CTA”) and the reporting requirements thereunder that was issued back in December by a federal court in Texas in connection with one of the pending cases challenging the constitutionality of the CTA (Texas Top Cop Shop, Inc. v. McHenry – formerly, Texas Top Cop Shop v. Garland).
The New York State Department of Labor has issued guidance concerning the Paid Prenatal Leave Law that went into effect on January 1, 2025.
The guidance clarifies that prenatal leave is a separate leave bank. It is available to employees on the first day of work, without a need to accrue time. This paid prenatal leave is available to all employees in the private sector in New York State, regardless of the size of the employer.
On December 26, 2024, the merits panel of the Fifth Circuit Court of Appeals vacated the stay of the district court’s preliminary injunction enjoining enforcement of the Corporate Transparency Act (the “CTA”) and the reporting requirements thereunder that was issued earlier this week by the motions panel of the Fifth Circuit Court of Appeals. This means that the nationwide preliminary injunction issued by the district court on December 3, 2024 is back in effect and, for the time being, Reporting Companies are not required to comply with the Act or file Beneficial Ownership Information Reports (“BOI Reports”).