On August 11, 2026, the United States Treasury Department Financial Crimes Enforcement Network (“FinCEN”) announced changes to the Corporate Transparency Act (“CTA”), which changes definitively repeal any arguably applicable reporting requirements for community associations and board members, among others. The changes went into effect on August 14, 2026, by a final rule promulgated by FinCEN.

Now, U.S. Persons no longer need to report BOI, definitively establishing that no community associations are subject to CTA’s reporting requirements.

In January 2021, the CTA was passed, requiring certain “U.S. Persons” (i.e., United States citizens or residents, domestic partnerships, domestic corporations, estates other than foreign estates, and certain trusts) to report beneficial ownership information (“BOI”) to FinCEN. Such entities and those who owned and controlled them were required to report BOI under the CTA. While it has been our office’s position that the requirements of CTA were not applicable to typical condominium trusts in the Commonwealth, there was an argument that CTA was applicable to certain community associations.

Now, U.S. Persons no longer need to report BOI, definitively establishing that no community associations are subject to CTA’s reporting requirements. FinCEN has also announced that it will delete information previously reported by now-exempt entities and individuals. A fully detailed explanation of all the recent changes to the CTA under the new rule can be found here: Federal Register: BOI Reporting Requirement Revision.