For the past two years, one federal filing requirement has quietly hung over HOA and condo boards: the Corporate Transparency Act’s (CTA) beneficial ownership information (BOI) report. Associations were being asked to submit personal information on record, names, home addresses, dates of birth, to a federal database, simply because volunteers agreed to serve.
That requirement is gone for most associations.
On August 11, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule permanently ending BOI reporting requirements for community associations and most other U.S. entities. The rule took effect August 14, 2026. The requirement that had worried volunteer board members since the CTA took effect no longer applies to them.
Here’s what changed, what it means for your association, and what still needs watching. (For the original industry writeup this post is based on, see CAI’s HOAresources coverage.)
What the Corporate Transparency Act Required in the First Place
The CTA was written to fight money laundering and shell-company abuse. It required many entities registered with a state, including HOAs and condo associations, to report information about their “beneficial owners” to FinCEN. For some associations, that meant reporting on individuals who met the law’s definition of a beneficial owner or company applicant, which in practice often included board members with real control over association decisions: names, home addresses, dates of birth, and photo ID numbers, submitted to a federal database.
Boards and management companies raised the obvious objection. Volunteer HOA leaders are not the shell-company operators this law was written to catch. They are neighbors who agreed to serve on a committee. Handing over personal identification to a federal database felt like a mismatch between the law’s intent and its reach.
The New Rule, Plainly
FinCEN’s final rule removes the BOI reporting requirement for U.S. companies and individuals, community associations included, with one notable exception. That means:
- Associations no longer need to file a BOI report, current or future
- Associations no longer need to update or correct information already submitted
- FinCEN says it will delete previously reported information it reasonably believes belongs to a U.S. person, such as data tied to a U.S. passport or driver’s license
- Individuals who already received a FinCEN identifier do not need to take further action
- Foreign entities registered to do business in the U.S. still must report their foreign beneficial owners, though they no longer have to report on U.S. persons or company applicants
For the vast majority of associations, this obligation is over as of the rule’s effective date.
This Is a Regulatory Change, Not a Repeal
Here’s the distinction boards should hold onto: the CTA itself is still law. FinCEN’s rule changes how the law is applied and who it applies to. It does not erase the statute from the books.
That distinction matters more than it sounds like it should. A future administration or a court challenge could, in theory, revisit how the rule is enforced. Full repeal would take an act of Congress.
One bill aimed at doing exactly that is already moving. Rep. Warren Davidson introduced H.R. 425, the Repealing Big Brother Overreach Act, which would formally repeal the CTA outright. According to CAI, an amended version of the bill would also require FinCEN to delete previously collected BOI data within 90 days of enactment. The House Financial Services Committee approved that amended version in a close 26-25 vote in April, and the bill has since been placed on the House calendar. It’s still waiting on a vote from the full House.
So the practical burden on your association is gone. The underlying legal framework is not, at least not yet.
Why This Change Happened
This didn’t happen in a vacuum. Community Associations Institute (CAI), the industry’s national advocacy and trade organization, pushed back on this requirement since it was first introduced, submitting regulatory comments, engaging federal policymakers, and educating association leaders about a rule that kept shifting under their feet.
In September 2024, CAI went further and filed a federal lawsuit against the Treasury Department, arguing that volunteer board members were swept into a law never meant for them. That advocacy, combined with a 2025 interim rule that had already paused the reporting requirement, laid the groundwork for this permanent change.
It’s a reminder of something worth sitting with: policy affecting HOAs doesn’t just happen to boards. It gets shaped, sometimes successfully, by people paying attention on their behalf.
What Your Board Should Actually Do Now
For most associations, the to-do list here is short. That’s the good news.
- Confirm your association falls under the new exemption rather than the foreign-entity carve-out
- If your association previously filed a BOI report, keep those records per your normal retention practice; no new filing or update is required
- Stop tracking any internal deadline or reminder tied to the old reporting requirement
- Flag the rule change at your next board meeting so members stop wondering about it
- Watch H.R. 425 if full repeal matters to your association
The Bigger Picture for Boards
This is one compliance line coming off a long list that board members already carry. It won’t be the last federal or state requirement your association has to track, but it’s a useful example of why staying current on regulatory changes matters as much as running a good meeting or reviewing a good budget.
That’s part of what professional management is for. Not just handling the paperwork, but knowing which paperwork no longer applies. If your board isn’t sure which requirements still apply to your association, or which ones are now outdated, the team at Wise Property Solutions can help you sort current requirements from yesterday’s paperwork.
This post is for general information only and isn’t legal advice. If you have questions about your association’s specific situation, talk to your association’s attorney.
