Academy/Taxes, Audits & Financial Compliance
Beneficial-ownership/compliance developments
A federal rule that once worried board members nationwide was repealed in 2026. Here is what changed and what to check now.
No. As of a FinCEN final rule effective August 14, 2026, no U.S.-formed entity, including a homeowners association's corporation, has a beneficial ownership information (BOI) filing obligation under the Corporate Transparency Act. Board members do not need to file, update, or confirm anything with FinCEN. Federal rules can change again, so verify current status at fincen.gov/boi before relying on this.
What changed
For several years, the Corporate Transparency Act (CTA) required many U.S. entities to file beneficial ownership information with FinCEN, naming the individuals who own or control them. Uncertainty during that period led many associations to treat their own board members as reportable beneficial owners of the association's corporation.
On August 14, 2026, the U.S. Treasury and FinCEN issued a final rule that exempts every domestic reporting company, meaning no U.S.-formed entity has a BOI obligation going forward. Community Associations Institute confirmed the change reaches community association boards specifically, ending years of uncertainty about whether board members counted as reportable owners.
What this means for your board
Nothing to file. No board member, officer, or the association itself needs to submit, update, or renew a BOI report with FinCEN. If someone on your board filed a BOI report in an earlier year, no follow-up action is required.
FinCEN also said it will delete previously submitted BOI data belonging to U.S. persons who are now exempt, including board members who filed under the old rule. You do not need to request that deletion; it is part of the rule itself.
This does not touch your other filings
BOI reporting was always a Treasury anti-money-laundering filing, separate from your association's tax return, state corporate filings, and registered agent requirements. Its repeal changes nothing about whether you owe federal tax, file Form 1120-H or Form 1120, or keep your state registration current.
Some states have their own beneficial-ownership or foreign-entity disclosure rules, separate from the federal CTA. Confirm with your secretary of state or a local attorney whether any state-level version applies to your association.
Check yourself
Answer before you read the explanation, recalling it is what makes it stick.
A board member filed a BOI report with FinCEN back in 2023. After the August 2026 final rule, what should they do now?
A departing board member is worried their name is still on file with FinCEN from a report filed years ago. What does the final rule do about that record?
Your association has filed Form 1120-H accurately every year. Does that satisfy any federal beneficial-ownership reporting requirement?
Sources
- Beneficial Ownership Information Reporting Requirement Revision, final rule, FinCEN / U.S. Treasury, Federal Register
- Breaking News: U.S. Treasury and FinCEN Issues Final Rule Ending Corporate Transparency Act's Beneficial Ownership Reporting Requirements for Community Association Board Members, CAI Advocacy Blog, Community Associations Institute
Taxes, Audits & Financial Compliance
Now that BOI is off your list, make sure your state filings are just as current: see Corporate registrations.
Federal rules on beneficial ownership reporting have changed more than once; verify current status at fincen.gov/boi before relying on this staying permanent. Any state-level beneficial-ownership or entity-disclosure requirement is separate from the federal CTA and varies by state.