Corporate Transparency

The Corporate Transparency Act was enacted by Congress on January 1st, 2021, as part of the National Defense Authorization Act. In accordance with the Act, The United States Department of the Treasury has established the FinCEN Bureau to collect and analyze information about financial transactions to combat money laundering and terrorist financing.

The reporting requirements of the Act take effect on January 1st, 2024 and the first round of reports must be filed by January 1, 2025. Thereafter most businesses must file reports to FinCEN via their website as “reporting companies” or face fines and penalties. Community associations, including homeowner and condominium associations, are corporate entities and fall under the FinCEN definition of a “reporting company”. This regulation will have an enormous impact and there is still potential for it to be modified. For more references, details, and the most up-to-date information, please visit the Community Association Institute’s website.

The reports that must be filed to FinCEN are called “Beneficial Owner Information Reports” and include information about the company and each person who exercises control over the corporation, known as a “Beneficial Owner”. For the purpose of this reporting, a Beneficial Owner is any individual who, directly or indirectly through any contract or relationship, exercises substantial control or owns 25% or more of the entity. In homeowner and condominium associations, the beneficial owners are the then-current board of directors as they exercise substantial control of the association. Each Beneficial Owner must report their full legal name, date of birth, current address, and a legible copy of their passport or driver’s license. Alternatively, board members can apply individually for a FinCEN identifier, negating the need to provide their passport or driver’s license. 

Eclipse offers completion of the Beneficial Owner Information Report on behalf of the community associations that have engaged us to do so. Please complete the form below to provide our team with the necessary infomration to complete this report for your association. If you have any questions on the process, please feel free to give us a call at (513) 494-4049.