Update, September 8, 2026: this requirement no longer applies to community associations. On August 14, 2026, FinCEN published a final rule (91 FR 52508) that permanently removes domestic entities from the definition of a reporting company and exempts United States persons from being reported. An association incorporated under state law now has no obligation to file a beneficial ownership information report, no obligation to update or correct anything it filed during the window when reporting was required, and no need to withdraw a prior filing. FinCEN has said it will delete the previously reported information itself, so boards do not need to take any action. Two caveats are worth keeping in mind. The Corporate Transparency Act statute was not repealed, only the rule was changed, so the exemption exists by regulation. And several states are weighing their own transparency laws, which is where any future obligation is most likely to appear. Current federal guidance is at fincen.gov/boi, and CAI’s summary for community associations is here. The original post is preserved below as it was written.
As of March 21, 2025, FinCEN issued an interim final rule removing the requirement for U.S. companies and U.S. persons, including community associations, to report beneficial ownership information under the CTA. This change effectively exempts domestic entities from the CTA’s reporting requirements.
While this is a significant development, it’s important to note that this interim rule is subject to change, and FinCEN is accepting public comments before finalizing the rule. CAI continues to participate in this process to advocate for the interests of community associations.
What Community Associations Should Do Now
Stay Informed: Monitor updates from CAI and FinCEN regarding the CTA and its requirements.
Engage in Advocacy: Consider reaching out to your congressional representatives to express support for exemptions for community associations.
Maintain Compliance Readiness: Although the reporting requirement is currently suspended for domestic entities, it’s prudent to be prepared in case of future changes.
For more detailed information and resources, visit CAI’s Corporate Transparency Act resource page at https://www.caionline.org/advocacy/advocacy-priorities-overview/corporate-transparency-act/https://www.caionline.org/advocacy/advocacy-priorities-overview/corporate-transparency-act/. The leadership team at Eclipse will continue to monitor and update our business partners on any changes as well.
