The Corporate Transparency Act (CTA) is a U.S. law that was passed in 2021. It requires certain businesses to disclose ownership information to the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Department of the Treasury.

The federal law was created to increase business transparency and accountability to prevent illegal activities, particularly financial crimes including fraud, money laundering, and tax evasion.

There are 23 different entities that are exempt from the Corporate Transparency Act including different types of credit unions, insurance companies, public utilities, and securities exchanges.

However, the Corporate Transparency Act’s broad language could potentially impact community associations and cooperatives based on how they are legally structured. If a condominium, homeowner (HOA), townhome association or co-op is classified as a domestic reporting company under the Corporate Transparency Act, then the association could be subject to the Act’s reporting requirements.

The Corporate Transparency Act takes effect on January 1, 2024. While the deadline for compliance with the CTA requirements is set for January 1, 2025, board members and property managers cannot ignore the impact of this new law and will need to demonstrate a sense of urgency to comply including:

  • Confirming the community association is subject to the Corporate Transparency Act
  • Providing proper personal identification to the U.S. Department of the Treasury
  • Filing the correct documentation with the U.S. Department of the Treasury

Additionally, the Act specifies that the U.S. Department of the Treasury must be updated if there are changes to board of directors from the community association’s initial filing.


Next Steps for Board Members and Property Managers

Based on the Corporate Transparency Act’s current broad language, board members would also be defined as having “substantial influence over important decisions” as “beneficial owners” within the association. Accordingly, board members would need to provide the required personal information and documents to the U.S. Department of the Treasury.

A property management company may also be considered to have similar “substantial influence over important decisions” impacting the community association, requiring the management company to also fulfill the Act’s requirements.

Board members and property managers should reach out to the association’s legal counsel and accounting professionals to acquaint themselves with the filing requirements of the Corporate Transparency Act.


Legal Resource

Contact our law firm if you have questions regarding the Corporate Transparency Act, reporting requirements, and the Act’s potential impact to your homeowner association (HOA).

KSN can assist in preparing the documentation that complies with the Act including protocols to promptly learn about any changes to the association’s “beneficial owners” and/or updates to their Personally identifiable information (PII) that must be submitted within the required reporting timeframe.

You can reach KSN by calling 855-537-0500 or visiting our website at


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