What is BOI reporting?
BOI, or Beneficial Ownership Information, reporting was a Corporate Transparency Act requirement that once applied to many HOAs structured as corporations or LLCs, requiring them to identify and report the individuals who control them. That’s no longer true for domestic associations: a FinCEN interim final rule issued in March 2025 redefined “reporting company” to mean only foreign entities registered to do business in the US, exempting every US-formed HOA, condo association, and US person along with it.
Why does BOI reporting matter?
For a while this caught boards off guard, since nothing about running a volunteer neighborhood association feels like it should trigger a federal anti-money-laundering filing, and yet for many HOAs it technically did. FinCEN closed that chapter for good with a final rule effective August 14, 2026, making the exemption permanent rather than just interim, and the agency announced the change in a release titled “FinCEN Permanently Ends Beneficial Ownership Reporting Requirements for Millions,” directing the deletion of BOI data it had already collected from now-exempt filers.
When You’ll Run Into This
This tends to come up once, when a board first learns the requirement exists, usually from a lawyer or accountant rather than from anywhere obvious. It’s worth confirming your HOA’s filing status now rather than finding out the hard way.
