Updated February 19, 2025
Beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA) are again in effect.
On February 18, 2025, the last remaining injunction against the CTA was lifted by a U.S. District Court for the Eastern District of Texas. The court’s decision reinstates the BOI reporting requirements for entities subject to the CTA.
In response to the court’s decision, the Financial Crimes Enforcement Network (FinCEN) announced a revised filing deadline for BOI reports. Pre-existing companies (those formed prior to January 1, 2024, which is most of our community association clients) now have until March 21, 2025 to submit their BOI reports. For full details on the filing deadline extension, you can download FinCEN’s announcement here.
The CTA, as originally enacted, applies to most community, subdivision, and condominium associations, as well numerous other entities, by requiring them to disclose their beneficial ownership to the federal government. For more background on the CTA and its implications for associations, see our prior article here.
