Overview
The Corporate Transparency Act (CTA) is a federal law originally enacted to prevent money laundering and financial crimes by requiring most U.S. companies to disclose their “beneficial owners” to the Financial Crimes Enforcement Network (FinCEN).
When first implemented in 2024, the law appeared to include most homeowners associations (HOAs) as entities required to file Beneficial Ownership Information (BOI) reports. However, as of 2025, enforcement of this requirement for associations has been suspended nationwide following court rulings and subsequent regulatory changes.
Current Status (as of 2025)
In March 2025, FinCEN announced an interim final rule removing the BOI reporting requirement for U.S. entities, including HOAs.
Earlier, a federal court injunction temporarily halted enforcement of the CTA across the country.
As a result, HOAs are not currently required to file BOI reports, and no penalties apply for non-filing while enforcement remains suspended.
Although the law itself still exists, its implementation is paused. Future court decisions or federal updates could change this status.
What the CTA Was Designed to Require
If reinstated in the future, the CTA would require entities such as HOAs to report:
The association’s legal name and address
The names and identifying information of “beneficial owners” (typically Board members)
The name of the person or entity who filed the association’s incorporation documents
Reports would be filed electronically with FinCEN and updated whenever board membership or association details change.
What HOAs Should Do Now
While filing is not currently required, Your HOA Community Management recommends that Boards:
Stay informed about updates to the CTA and any future enforcement changes.
Keep current records of board members and corporate filings with the Secretary of State.
Be prepared to file if federal requirements resume in the future.
Your HOA will continue monitoring legal developments and will alert communities if filing obligations return.
Avoiding Confusion
Some third-party websites still advertise “filing services” or “urgent deadlines” for CTA reports. These are unnecessary for HOAs at this time. Always verify compliance information through official government or management channels before submitting personal data or payments.
Reliable Sources
FinCEN official website: https://fincen.gov
HOA industry update (Associa): https://hub.associaonline.com/blog/boi-filing-deadline-2025
Legal update (KSN Law): https://www.ksnlaw.com/blog/corporate-transparency-act-temporarily-halted-nationwide-community-association-board-members
Contact
For questions about the CTA, or to confirm your association’s corporate records, email homeowners@yourhoahelp.com.
Importance
While the CTA’s enforcement is currently suspended, HOAs should remain informed and ready in case reporting requirements resume in the future. Your HOA Community Management will continue tracking updates and ensuring associations stay compliant if changes occur.