FinCEN Removes Reporting Requirements for the Board Members of a Condo Association or an HOA under the Corporate Transparency Act (CTA)

For the past several years, condominium, HOAs, and other common interest community associations have faced considerable uncertainty over whether their board members would be required to report personal information to the federal government under the Corporate Transparency Act (“CTA”). After multiple rule changes, court challenges, and shifting compliance deadlines, that uncertainty is finally over.

On August 11, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) permanently ended the reporting requirements for U.S. companies, including all condo, HOAs, and other common interest community associations, to report beneficial ownership information (“BOI”) to FinCEN under the CTA. FinCEN also announced that it will delete all previously reported BOI information from its database.

How Did We Get Here?

In 2021, Congress enacted the CTA as part of its attempts to combat financial crimes conducted through anonymous shell companies. Under the CTA, FinCEN created a database identifying individuals who own or substantially control most corporations and similar companies created by filing documents with a state, i.e. articles of incorporation, including most condominium and common interest community associations.

FinCEN’s original regulations became effective January 1, 2024. Before the original reporting deadlines, the CTA became the subject of extensive litigation. Federal courts issued competing rulings concerning the constitutionality of the Act and several nationwide injunctions stopping enforcement of the reporting requirements. In January 2025, the U.S. Supreme Court stayed one nationwide injunction, although a separate injunction temporarily continued to prevent enforcement.

In March 2025. FinCEN announced an interim rule exempting entities formed in the United States from BOI reporting requirements. It finalized this rule on August 11, 2026, permanently ending all BOI reporting requirements for U.S. companies.

As a result, condo, HOAs, and other common interest community associations no longer had to file BOI reports with FinCEN.

How Does This Apply to Your Association?

The practical result for your associations is simple: condo, HOAs, and other common interest community associations no longer have to file BOI reports with FinCEN. Volunteer board members are no longer required to report their personal information to the federal government simply because they sit on an associations’ board of directors.

For more information about this latest FinCEN announcement, or other HOA or condo association matters, contact Attorney Robyn Kisk, at 847-705-7555 or rkish@lavellelaw.com.