The judicial whiplash has come to an end and associations no longer need to worry about complying with the Corporate Transparency Act. On March 2, 2025, the U.S. Treasury Department announced significant changes to the enforcement of the Corporate Transparency Act’s (CTA) beneficial ownership information (BOI) reporting requirements. In a major policy shift, the Treasury Department confirmed that it will not enforce any penalties or fines related to the BOI reporting rule under the existing deadlines. Furthermore, once forthcoming rule changes take effect, penalties and fines will not be enforced against U.S. citizens, domestic reporting companies, their beneficial owners, or entities such as homeowners associations (HOAs) that were previously subject to these requirements.
In addition, the Treasury Department will narrow the scope of the CTA to apply only to foreign reporting companies. This move is intended to support American taxpayers and small businesses, including HOAs, while ensuring the rule remains aligned with the public interest.
This means that HOAs will not need to complete and submit the BOI reporting statement. Additional details on the proposed rule-making and next steps will be released in the coming weeks.
Have questions? Contact your favorite HGCT attorney to further discuss.