Last week, the District Court for the Eastern District of Texas held that the Corporate Transparency Act (“CTA”), which took effect January 1, 2024 with a reporting deadline of December 31st, “appears likely unconstitutional,” and entered an injunction against the CTA’s enforcement. Since then, FinCEN has announced that “While this litigation is ongoing, FinCEN will comply with the order issued by the U.S. District Court for the Eastern District of Texas for as long as it remains in effect. Therefore, reporting companies are not currently required to file their beneficial ownership information with FinCEN and will not be subject to liability if they fail to do so while the preliminary injunction remains in effect. Nevertheless, reporting companies may continue to voluntarily submit beneficial ownership information reports.” While it would seem to follow that an extension would be granted to file beneficial ownership information in the case the injunction is lifted and enforcement begins, some more clarity from FinCEN would be appreciated.