As you all know, the reporting requirements for the Corporate Transparency Act (“CTA”) have been somewhat of a roller coaster for the past year. Our industry has never experienced anything like this before. Reporting requirements are on, then off, then back on, and now hopefully there will be a new emergency ruling that will eliminate reporting requirements for the CTA for all Board members.

The new Secretary of Treasury, Scott Bessent, just made an announcement that the U.S. Treasury Department would no longer enforce the CTA against domestic companies or U.S. Citizens. Mr. Bessent referred to a new emergency rule (which has yet to be implemented) that the U.S. Treasury Department will only enforce the CTA requirements against foreign companies. That being said, the conclusion is that community association Board members will no longer be required to comply with the CTA reporting requirements.

Just last week, we heard the CTA reporting requirements were reinstated and that no later than March 21, 2025, the U.S. Treasury Department was going to implement a final ruling on the CTA requirements. As there are further updates, we will be sure to provide you with any new information we receive about the CTA and reporting requirements as the emergency rule and any other relevant information develops.

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.