Joliet Jake and Elwood Blues famously perform a remake of the The Chips song “Rubber Biscuit” on SNL.  

It’s a silly song – the lyrics are mostly gibberish, for example, they start “Cow cow hoo-oo Cow cow wanna dib-a-doo Chicken hon-a-chick-a-chick hole-a-hubba…” (and get more ridiculous from there)

Every time I think about the Corporate Transparency Act (CTA), this song comes to mind – more so lately because the CTA has been enjoined nationally, un-enjoined, and then re-enjoined in the span of just a few days in December.  If you are keeping tally, it is currently enjoined nationwide as of the posting of this article. 

Worse, after it was un-enjoined nationwide, FinCEN decided to allow only 13 days (the number of days it was enjoined) as an extension.  Even more oddly, when the CTA was first enjoined many months ago, the court said the CTA was unconstitutional, but then only enjoined its enforcement against the particular plaintiffs in the case – complicating any meaningful timely nationwide review.

Many of our clients have filed their Business Owner Information reports at FINcen (Website), and our advice is to either do so, or prepare on short order to do so. Their webpage states: “[A]s of December 26, 2024 … the injunction issued by the district court in Texas Top Cop Shop, Inc. v. Garland is in effect and reporting companies are not currently required to file beneficial ownership information with FinCEN.” While we feel some of the regulations they issued may have to be adjusted – it is likely the law will survive in some form or another. However, if you have not filed, or form a new company and do not want to file, as of now, there is no legal obligation to do so, and when its finally resolved, we can do the rubber biscuit song hopefully one more time . . .