Reporting requirements for the Corporate Transparency Act (“CTA”) have been put back in place for community associations following several legal attempts to permanently enjoin the measure. The United States Treasury Department and the Financial Crimes Enforcement Network have extended the reporting deadline to March 21, 2025.

Associations who have not yet reported their beneficial ownership status of directors should now be taking steps to complete the reporting process. Board members are required to provide your name, date of birth, address, and a valid current drivers’ license or U.S. Passport. There are online and pdf filing instructions within the links below so if you would like to go directly to the filing instructions, here are the online and PDF links for filing with FinCEN:

Online filing instructions https://boiefiling.fincen.gov/resources/BOIR_E-File_Online_Step-by-Step_Instructions.pdf

PDF filing instructions  https://boiefiling.fincen.gov/resources/BOIR_E-File_PDF_Step-by-Step_Instructions.pdf

Board members can face personal liability for not reporting to FinCEN by the March 21, 2025, deadline. There is a civil penalty of $500/day and criminal penalties of up to $10,000.00 and 24 months in prison for each beneficial owner that fails to report. Each association or board member must file a report with FinCEN and update that information within 30 days of any change.

While the law is intended to combat illegal activities including funding of terrorist organizations and money laundering. This extremely broad approach has, and continues to be, opposed by many groups including the Community Association Institute (“CAI”). CAI filed a lawsuit in September of 2024 seeking an injunction against the act. Unfortunately, that injunction was denied by the court. An appeal is pending in that matter.

  If your association has questions or concerns about the status of the Corporate Transparency Act and its reporting obligations, please contact Williams & Strohm, LLC at 614-228-0207 and speak with one of our attorneys.