On March 26, 2025, U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an interim final rule and request for comments. The interim rule eliminates the requirement under the Corporate Transparency Act (CTA) for U.S.-based entities, including community associations, and their board members to report beneficial ownership information to FinCEN.
As a result, subject to further rule changes, community associations are no longer required to file an initial Beneficial Ownership Information Report (BOIR) or update or correct a previously submitted BOIR.
In practical terms, this means that condominium, homeowner (HOA), and townhome community associations formed or organized within the United States or under an Indian tribe, along with their board members and officers, are now exempt from the CTA’s BOIR filing requirements.
As noted in FINCEN’s March 26, 2025 statement:
“FinCEN is adopting this interim final rule to narrow the existing beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA) to require only entities previously defined as “foreign reporting companies” to report BOI. Under this interim final rule, entities previously defined as “domestic reporting companies” are exempted from the reporting requirements and do not have to report BOI to FinCEN, or update or correct BOI previously reported to FinCEN.”
You can read the FinCEN interim rule here: https://www.federalregister.gov/documents/2025/03/26/2025-05199/beneficial-ownership-information-reporting-requirement-revision-and-deadline-extension
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KSN will continue to monitor the situation, the status of the Corporate Transparency Act (CTA), and its impact on community associations.
You can reach KSN by calling 855-537-0500 or visiting our website at www.ksnlaw.com.
Since 1983, KSN has been a legal resource for condominium, homeowner, and townhome associations. Additionally, we represent clients in real estate transactions, collections, landlord/tenant issues, and property tax appeals. We represent thousands of clients and community associations throughout the US with offices in several states including Florida, Illinois, Indiana, and Wisconsin.
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