Corporate Transparency Act Update

Corporate Transparency Act Update: What HOA Boards Need to Know About BOI Reporting

Updated August 14, 2026

If your HOA board has heard about the Corporate Transparency Act, Beneficial Ownership Information, or “BOI” reporting, you may have questions about whether your association needs to file a report with the federal government.

The answer has changed significantly.

On August 11, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network, or FinCEN, issued a final rule permanently removing the federal BOI reporting requirement for U.S. companies and U.S. persons. The rule became effective August 14, 2026.

For most U.S.-created homeowners associations, this means there is no longer a federal BOI report to file.

What Is the Corporate Transparency Act?

The Corporate Transparency Act, often called the CTA, was created as part of the federal government's efforts to make it harder for individuals to hide illicit financial activity behind anonymous companies.

The law established requirements for certain businesses to provide information about the individuals who own or control them to FinCEN, a bureau of the U.S. Department of the Treasury.

That information is known as Beneficial Ownership Information, or BOI.

In simple terms, the original reporting requirement was designed to answer a basic question:

Who is actually behind this company?

When the original requirements took effect, they created significant questions for community associations. HOA and condominium boards are often made up of volunteer homeowners, and there was uncertainty about whether those volunteer directors could be considered individuals with substantial control who would need to provide personal information to the federal government.

Why Were HOA Boards Concerned?

The CTA was written to address concerns surrounding money laundering, illicit finance and the use of anonymous business entities.

Community associations, however, presented a different situation.

HOAs are generally governed by homeowners who volunteer to serve on their boards. Those directors are elected to make decisions on behalf of their communities, rather than to operate a company for personal financial gain.

That distinction became an important issue for the community association industry.

CAI Advocated for Community Associations

The Community Associations Institute (CAI) has been actively advocating for community association board members to be exempt from the CTA's BOI reporting requirements.

According to CAI, the organization raised concerns about the compliance burden and privacy implications for associations and their volunteer leaders. CAI engaged with federal policymakers and FinCEN, submitted regulatory comments, mobilized advocates and educated community association professionals throughout the changing requirements.

CAI also filed a federal lawsuit against the U.S. Treasury Department in September 2024 challenging the application of the CTA to community associations.

Now, that advocacy has resulted in a significant change for community association boards.

In its August 12, 2026 update, CAI summarized the new rule this way:

“U.S. companies and U.S. persons, including community association board members, are permanently exempt from beneficial ownership information reporting requirements.”

What Changed?

The latest rule builds on changes FinCEN made in March 2025.

At that time, FinCEN removed the BOI reporting requirement for entities created in the United States and U.S. persons. The 2026 final rule makes those changes permanent.

Under the current rule:

U.S.-created companies are exempt from BOI reporting.
U.S. persons are exempt from providing BOI under the rule.
Community association board members who are U.S. persons are included in that exemption.
U.S. persons who previously obtained FinCEN identifiers do not need to update or correct that information.
FinCEN plans to delete previously reported information that it reasonably believes was provided by U.S. persons who are now exempt.

What Does This Mean for HOAs?

For a homeowners association that was created in the United States, the current federal rule means the association is exempt from BOI reporting.

For HOA boards, this is the key takeaway:

Your volunteer board members generally do not need to submit personal information to FinCEN under the federal BOI reporting requirements.

This is particularly important because boards may still encounter older articles, emails or solicitations stating that they need to file a BOI report.

Those materials may be based on earlier versions of the rule.

The requirements have changed substantially since the CTA first took effect.

What If Your HOA Already Filed a BOI Report?

Some associations and board members may have already submitted information under the previous requirements.

Under the new rule, U.S. persons who previously obtained FinCEN identifiers do not need to update or correct that information. FinCEN has also announced plans to delete previously reported information that it reasonably believes was provided by U.S. persons who are now exempt.

If your association previously submitted a BOI report, keep your records and consult the association's attorney if you have questions about your specific circumstances.

Is the Corporate Transparency Act Gone?

This is an important distinction. The Corporate Transparency Act itself has not been repealed. The new rule changes how the law is applied by establishing exemptions for U.S. companies and U.S. persons.

CAI points out that the CTA remains part of federal law. A federal agency can change its regulatory requirements, but repealing the underlying statute would require Congress to pass legislation.

CAI is continuing to support federal legislation that would repeal the CTA entirely, including H.R. 425, the Repealing Big Brother Overreach Act.

Are There Still BOI Reporting Requirements?

Yes, but they are much narrower.

Certain foreign entities registered to do business in the United States can still be subject to BOI reporting requirements. Under the current rule, those foreign reporting companies generally report information concerning foreign individuals who qualify as beneficial owners.

For a typical HOA formed in the United States, this foreign-entity requirement generally will not apply.

What Should HOA Boards Do Now?

For most U.S.-created HOAs, there is no federal BOI filing to complete under the current rule.

Boards should:

1. Be aware of the latest rule.
Older information about mandatory BOI reporting may no longer apply.

2. Be cautious about unsolicited BOI notices.
Boards may continue to receive emails, letters or invoices offering to prepare BOI filings. Verify whether any action is actually required before providing personal information or paying a fee.

3. Keep your records.
If your association previously filed information, maintain appropriate records and consult your association's legal counsel with questions about the specific filing.

4. Watch for future changes.
The CTA remains federal law, and additional legislative or regulatory changes could occur.

The Bottom Line

The Corporate Transparency Act created a federal reporting requirement that raised significant questions for community associations and their volunteer board members.

After years of regulatory changes, legal challenges and advocacy from organizations including CAI, the current federal rule provides a clear answer for U.S.-created entities.

As of August 14, 2026, U.S. companies and U.S. persons, including community association board members, are permanently exempt from federal BOI reporting requirements.

For HOA boards, that means the BOI reporting requirement that generated so much concern is currently no longer something most U.S.-created associations need to navigate.

For the latest federal information, visit FinCEN's Beneficial Ownership Information resources. CAI's advocacy update is also an excellent resource for community association professionals following this issue.

This article is intended for general educational purposes and should not be considered legal advice. HOA boards should consult qualified legal counsel regarding questions about their specific association.

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