Navigating the Corporate Transparency Act: Brace Yourself for Stricter Oversight for HOA Boards
US community associations have nothing to file under the Corporate Transparency Act. FinCEN's final rule of 11 August 2026 exempts entities formed in the United States from beneficial ownership reporting, so neither the association nor its volunteer board members file an initial report, and nothing filed earlier needs updating or correcting.
Update, September 2026: this no longer applies to US associations. FinCEN issued a final rule on 11 August 2026 exempting entities formed in the United States from beneficial ownership reporting. Homeowner and condominium associations in the US, and their volunteer board members, have no report to file and no deadline to meet.
What changed
- FinCEN issued a final rule on 11 August 2026. It makes permanent the exemptions set out in the interim final rule of March 2025. The rule took effect on 14 August 2026 and was published in the Federal Register.
- Entities formed in the United States are exempt. A company created by filing with a US state or tribal authority is no longer a reporting company.
- US community associations have nothing to file. An HOA or condominium association incorporated in a US state is a domestic entity, so the requirement does not reach it, and it does not reach the volunteer board members who serve it.
- Nothing already filed needs updating. FinCEN states that exempt US entities file no initial report and do not update or correct reports filed earlier.
- Only certain foreign entities still report. A company formed abroad and registered to do business in a US jurisdiction may still have to file, and even then it does not report US person beneficial owners. FinCEN keeps the current position on its beneficial ownership information page.
Background: the original requirement (2024–2026)
What follows describes the requirement as it stood when the Corporate Transparency Act took effect. It is kept as a record of what boards were asked to do, and it no longer describes anything a US association must do.
When the CTA took effect, community associations were told to expect new obligations under the Corporate Transparency Act. Associations were to reveal board member information to the government, and that information was to be held in a database used to fight financial crime.
Why associations were caught by it
Congress enacted the CTA in 2021 to help fight fraud and corruption, and the Treasury used it to address money laundering through shell companies. The act was aimed at establishing who really owns a corporation, and community associations fell inside its definition of a reporting company.
It required most associations to disclose information about the individuals who controlled the association, which in practice meant the board. Before the CTA, that burden sat with financial institutions; the act moved it to the entity itself. The Financial Crimes Enforcement Network (FinCEN) was to compile the data, with access restricted to law enforcement rather than open to the public.
What associations were asked to report
Some non-profit groups were exempt and most associations were not. An association had to identify its beneficial owners, meaning the individuals with influence over its significant decisions, and report names, addresses and other identifying details. With over 350,000 community associations in the United States, the transition would have been a large one, and the compliance cost was expected to reach owners through their assessments.
The timeline that applied at the time
The rule took effect on 1 January 2024. Associations in existence on that date had until 1 January 2025 to submit an initial report, and associations formed after it had 30 days from formation. Those deadlines no longer apply to a US association.
Where this leaves your board
With nothing to file. A US association submits no beneficial ownership report and has no deadline to meet, and neither do the volunteer members who sit on its board. If your board had set time aside for this, that time is free for the decisions that do still need making, starting with how the association pays for the work ahead of it.
Contact HOA Loan Services to learn about financing options and to help answer all of your HOA capital raising questions.
Boards also ask
Is anyone in the association individually liable for the loan?
No. The association is the borrower. In the loans we arrange, board members sign on the association’s behalf, not personally: there’s no personal guarantee, and their credit isn’t pulled. The loan does not appear on any individual’s credit or affect their mortgage.
Does anyone’s credit score matter?
In the loans we arrange, no individual’s credit is pulled: not board members, not homeowners, not the property manager. Associations do not have credit scores in the consumer sense either. What stands in for one is your financial record: assessment collection history, delinquency rate, reserve funding level, and whether past obligations were met. That is the association’s credit, and unlike a personal score, your board can improve it deliberately.
Do all owners have to vote to approve the loan?
It depends on your CC&Rs and state law. Many boards can borrow without a full membership vote; some require one. We help you read your documents and plan the approval path before you commit.
What is an HOA loan?
An HOA loan is financing your association borrows as an entity to pay for a major capital project, then repays out of the assessments you already collect. It is underwritten against the association’s finances and its authority to levy assessments; not against individual homes.
Still deciding? Talk it through with us.
We’ll talk with any board at no charge and no obligation, just answers.