Starting January 1, 2025, condo and homeowners’ association (HOA) boards must file a Beneficial Ownership Information (BOI) report with the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN). This requirement stems from the Corporate Transparency Act (CTA), which was enacted in 2024 to help combat money laundering and terrorist financing, as well as to enhance national security.
While there are 23 categories of businesses exempt from this requirement, most condo and HOA communities do not fall into these exemptions. Many associations and management companies feel that this requirement is unfair, especially since FinCEN has noted that the domestic charitable sector poses a low risk for money laundering. There have been numerous lawsuits filed.
Community Associations Institute (CAI) v. U.S. Department of Treasury challenges the Corporate Transparency Act and its applicability to community associations nationwide.
- On October 24, a motion for a preliminary injunction was denied. This injunction aimed to delay the deadline for community associations to meet the act’s challenging requirements until the court could fully review the case.
- Consequently, community associations must still comply with the act’s requirements by January 1.
Although this ruling is not the outcome the Community Associations Institute (CAI) was hoping for, it does not signify the end of their efforts. Nonetheless, as of now, condo and HOA boards must prepare to submit their BOI reports by the deadline in 2025.
Please visit CAI’s Corporate Transparency Act resource page for additional information.
