Milwaukee County Housing Services would like housing providers to fill out their 2025 planning survey:
Take Survey Here
This survey asks for how informed you are about their services, and when you are available for attending online or in-person events in 2025.
By: Kirsten Fagerland Pezewski, Pezewski Law Offices, S.C.
December 28, 2024. FinCEN’s website at www.fincen.gov/boi has released another update regarding Texas Top Cop Shop, Inc. v. Garland. According to FinCEN: “as 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.”
Although a panel of the U.S. Court of Appeals granted a stay of the district court’s preliminary injunction on 12/23/24, and FinCEN posted an alert announcing updated deadlines for reporting companies to file beneficial ownership information, the Court of Appeals has moved quickly and issued an order on 12/26/24 vacating the Court’s 12/23/24 order which granted the stay of the preliminary injunction.
The rapid changes regarding the requirements to report together with FinCEN’s prior announced updated deadline dates illustrate the importance of monitoring the progress of the BOI litigation and ensuring that, if reporting companies are again required to report, they are ready to timely do so.
Because of the harsh penalties for failing to comply with the CTA and reporting requirements (criminal penalties of up to two years of imprisonment and a fine of up to $10,000 and/or civil penalties of $591 per day increased annually by inflation) it’s very important to continue to monitor the status of the Corporate Transparency Act and its reporting requirements, to see if the appeal or other action will again affect the injunction and what happens to the reporting requirements and deadline dates.
Please be sure that you are working with your accountant and/or attorney to monitor the status of the BOI reporting requirements for your own organizations, and that you understand the requirements and penalties for failure to comply with the CTA.
NOTICE THAT THIS IS NOT LEGAL ADVICE: The information in this blog post is provided for general informational purposes only. The information contained in this post should not be construed as legal advice from Rental Property Association of WI, Inc. or its individual author. Please seek appropriate legal or professional advice on the particular facts and circumstances that you may have at issue from a lawyer licensed to practice law in your state or jurisdiction if you wish to obtain legal advice about any matter.
NOTE: THIS POST HAS BEEN UPDATED BY THE 12/28/24 POST. The Department of the Treasury’s Financial Crimes Enforcement Network is back to enforcing its required Beneficial Ownership Information reporting with slightly delayed deadlines. These filing requirements apply to domestic and foreign corporations and limited liability companies and any other entities created with a filing with a secretary of state or other similar office. Please review FinCEN’s alert at https://fincen.gov/boi to determine the deadlines that apply for each of your business entities and to read the latest official alerts. BUSINESSES FORMERLY REQUIRED TO REPORT BY JANUARY 1, 2025 HAVE UNTIL JANUARY 13, 2025 TO FILE THEIR INITIAL BENEFICIAL OWNERSHIP INFORMATION REPORTS WITH FINCEN.
Because of the harsh penalties for failing to comply with the CTA and reporting requirements (criminal penalties of up to two years of imprisonment and a fine of up to $10,000 and/or civil penalties of $591 per day increased annually by inflation) it’s very important to determine if your business entity is required to report and by when.
New Management
From the Housing Authority of the City of Milwaukee (HACM):
Dear Housing Partners,
By order of the Housing Authority Board of Commissioners, the HACM Housing Choice Voucher program will be under the new management of CVR Associates beginning January 2, 2025. The voucher program will continue to operate as is: all contracts will continue to be honored, scheduled inspections will continue to occur, all housing payments will continue to be made on the first of each month. A more detailed account of this transition is available at this link on our website.
HACM and CVR are committed to making this transition as smooth as possible. A number of HACM Rent Assistance staff will be staying with the program as it transfers to CVR. Please stay tuned to your email as we will continue to provide updates through this format.
The transition to CVR and any other concerns you may have regarding the Housing Choice Voucher program are open for discussion at this month's virtual meeting on December 11, click the link below to join the meeting.
On behalf of all the Rent Assistance Program staff at HACM, thank you all for your ongoing partnership to provide affordable, quality housing to the voucher families in our community.
Steve Fendt
Landlord Outreach Coordinator
December Virtual Info Session for Section 8 Housing Providers
Wednesday, December 11, 2024 -- 10:00 AM - 11:00 AM
Microsoft Teams meeting
Join on your computer, mobile app or room device
Click here to join the meeting
Meeting ID: 291 278 921 882
Passcode: WUuwKK
Or call in (audio only)
414-251-0392
Phone Conference ID: 252 725 593#
By Kirsten Pezewski, Attorney, Pezewski Law Offices, S.C.
FOR NOW, FEDERAL COURT DECISION STOPS JANUARY 1, 2025 FILING REQUIREMENT FOR OWNERS OF CORPORATIONS AND LLCS
Good news for owners of corporations and LLCs that have not yet filed their beneficial ownership information with the federal government. A December 3, 2024 decision by a Texas district court has issued an injunction staying the requirement to report beneficial ownership information. This injunction is currently effective nationwide.
FinCEN has issued an alert stating that reporting companies are not currently required to file their beneficial ownership information and will not be subject to liability if they fail to do so while the injunction is in effect. https://fincen.gov/boi
However, this will likely not be the end of the story. The Department of Justice has already filed a Notice of Appeal on December 5, 2024.
Because of the harsh penalties for failing to comply with the CTA and reporting requirements (criminal penalties of up to two years of imprisonment and a fine of up to $10,000 and/or civil penalties of $591 per day increased annually by inflation) it’s very important to continue to monitor the status of the Corporate Transparency Act and its reporting requirements, to see if the appeal will affect the injunction and what happens to the reporting requirements and deadline dates.
With mixed emotions, we announce the retirement of Heiner Giese, the Rental Property Association of Wisconsin’s (RPA) devoted attorney and advocate for property owners for over 33 years. Since the early 1990s, Heiner has led RPA’s legislative and legal efforts, safeguarding the rights of rental property owners and fostering reasonable housing policies in Wisconsin.
Heiner began his journey with RPA alongside then-attorney Bob Smith, ultimately succeeding him when Bob retired. Over three decades, Heiner’s expertise and unwavering commitment have profoundly impacted our organization and the rental housing community.
Legislative Leadership
Heiner played a vital role in shaping local regulations, including lead paint rules, nuisance property ordinances, and property recording requirements, to minimize their impact on responsible property owners.
Between 2011 and 2018, Heiner and the RPA Legislative Committee, in close collaboration with the Wisconsin Realtors, spearheaded six landmark state bills that transformed Wisconsin’s rental laws. These included streamlining the eviction process, prohibiting local eviction moratoriums, restricting rental inspection programs, capping inspection fees, and ensuring owners could represent their LLCs in eviction court. (A detailed summary of these accomplishments will be available.)
These victories created a more equitable legal landscape for rental property owners across the state.
Legal Advocacy
Heiner has been a vigilant advocate for property owners in Milwaukee County Courts, working to ensure compliance with Wisconsin law and fair treatment for landlords.
At the state level, Heiner successfully argued before the Wisconsin Supreme Court to prevent sealing eviction cases after one year and helped secure a pivotal decision affirming owners’ rights to evict tenants for lease violations, such as illegal drug use.
Nationally, Heiner represented private rental owners through the National Housing Provider Coalition, collaborating with groups like the National Association of Realtors and submitting an amicus brief to the U.S. Supreme Court in a case challenging eviction moratoriums. He was the only rental owner representative at two national housing conferences in D.C.
A Legacy of Advocacy
Heiner oversaw RPA’s eviction study, countering anti-owner narratives. He also played a key role in the Milwaukee Rental Housing Coalition, ensuring more effective distribution of COVID Emergency Rental Assistance funds than owners in other areas.
Even as retirement nears, Heiner continues to guide the Association, working closely with his successor, Attorney Kirsten Pezewski, to ensure a smooth transition.
Thank You, Heiner
Heiner’s leadership and advocacy have profoundly shaped Wisconsin’s rental housing landscape and left an enduring legacy for property owners.
Thank you, Heiner, for 33 years of tireless dedication. You will be deeply missed, and we wish you all the best in your well-deserved retirement.
By Heiner Giese, RPA Attorney
At the meeting tonight:
Tim Ballering reelected as treasurer and board member by unanimous vote.
For the five board slots the five incumbents were running:
There were two write-ins -- Sam Stair and Ken Bartels.
The five successful candidates were Dawn, Marcus, Mike, Tristan and Sam. Adam McCarthy and Ken Bartels were not elected.
The new board now selects the President and four Executive Board members at the next board meeting.
At a special Board of Commissioners meeting on Wednesday, October 30, 2024, the Housing Authority of the City of Milwaukee’s (HACM) Board approved a resolution authorizing staff to finalize a contract with CVR Associates, Inc. to manage and operate its Section 8 Housing Choice Voucher Program.
“I appreciate the Board acting with urgency to approve the award of this contract, allowing us to finalize the contract and begin the transition,” said Willie L. Hines, Jr., HACM Secretary-Executive Director. “CVR is highly qualified, and we believe their expertise will help us complete the required federal corrective actions and return our Section 8 program to high-performer status.”
Read the Full Release Here
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