The Corporate Transparency Act (CTA) requires community associations to report identifying information about the persons who directly (or indirectly) exercise substantial control over the association or who own or control 25% or more of the ownership interests. Generally, such information about those persons includes their names, addresses, dates of birth, and the identifying numbers and issuers of either a government issued ID, State driver's license or U.S. passport. For community associations that existed before January 1, 2024, the deadline for filing their initial "beneficial ownership reports" with the Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Department of the Treasury, is January 1, 2025. Community associations will also need to submit a new filing whenever there is updated information (e.g., when there is an election that changes the composition of the Board of Directors, etc.). 

Although there are certain exemptions to this reporting requirement, most community associations do not currently qualify for those exemptions. Additional guidance regarding the beneficial ownership reports can be obtained from FinCEN's Small Entity Compliance Guide (Beneficial Ownership Information Reporting Requirements). 

Our Firm is available to assist our clients with any questions concerning these reporting requirements. For associations who are not currently working with our Firm, but are interested in doing so, please contact Manager of Client Relations Diane Weissberg at 1-877-31FIORE or by email at dweissberg@fiorelaw.com for assistance.