As Kaman & Cusimano clients are likely already aware, earlier this year, the US Treasury Department issued new guidance on the Corporate Transparency Act, and as a result community associations are no longer required to comply with the CTA’s reporting requirements.
The US Treasury division that oversaw the CTA, the Financial Crimes Enforcement Network (FinCEN), issued an interim final rule that suspended the CTA’s beneficial ownership reporting requirements for domestic entities, including community associations. This means:
- Only foreign entities registered to do business in the U.S. are now considered “reporting companies” under the CTA
- Domestic community associations, such as HOAs and condo associations, are exempt from filing Beneficial Ownership Information (BOI) reports.
Specifically for Community Associations:
- No need to file BOI reports with FinCEN in 2025 and beyond.
- No penalties for not reporting, as the requirement has been lifted.
- No issue for any entity that did submit to be in compliance
We appreciate and recognize the ongoing legal and legislative efforts by the Community Associations Institute (CAI) and the College of Community Association Lawyers (CCAL) played a major role in achieving this successful outcome for community association volunteer board members.
