# Corporate Transparency Act Reinstated: What HOAs Need to Know About the March 2025 Deadline

The landscape of regulatory compliance for Homeowners Associations (HOAs) has shifted significantly with recent developments concerning the Corporate Transparency Act (CTA). Following a series of legal battles, the beneficial ownership information (BOI) reporting requirements are back in effect, with a new deadline that HOA boards and management companies must prepare for. This comprehensive guide explains the latest CTA updates and what they mean for your association.

## Court Decisions Reinstate CTA Reporting Requirements

In a pivotal legal development, the U.S. District Court for the Eastern District of Texas lifted its injunction against the Corporate Transparency Act on February 17, 2025. This decision follows a Supreme Court ruling that overturned a nationwide injunction that had temporarily blocked enforcement of the CTA’s reporting mandates.

The reinstatement of these requirements means that millions of entities across the United States, including community associations such as HOAs and condominium associations, must now comply with the BOI filing obligations administered by the Financial Crimes Enforcement Network (FinCEN).

## Extended Deadline: March 21, 2025

In response to the court’s decision, FinCEN has established a new compliance timeline for affected entities. Most companies, including qualifying HOAs, now have until **March 21, 2025** to submit their initial beneficial ownership information reports, updates, or corrections.

This extension provides a short but critical window for HOA boards and management companies to gather the necessary information and complete their filings. The deadline applies to:

– Initial BOI reports for existing entities
– Updated BOI reports for entities that have experienced changes in beneficial ownership
– Corrected BOI reports for entities that need to amend previously submitted information

## What HOAs Need to Report Under the CTA

The Corporate Transparency Act requires reporting companies to disclose information about their beneficial owners—individuals who either exercise substantial control over the entity or own or control at least 25% of the entity’s ownership interests. For HOAs, this typically includes:

1. Information about board members who exercise substantial control
2. Basic identifying information about the HOA itself
3. Specific personal information about each beneficial owner, including:
– Full legal name
– Date of birth
– Current residential address
– Identification number from an acceptable document (such as a driver’s license or passport)
– Image of the identification document

## Is Your HOA Required to Report?

Not all HOAs are subject to the CTA’s reporting requirements. Several exemptions exist that may apply to community associations:

– **Tax-exempt status**: HOAs that qualify as tax-exempt entities under specific sections of the Internal Revenue Code may be exempt
– **Large operating companies**: Entities with more than 20 full-time employees, a physical office in the U.S., and over $5 million in gross receipts or sales
– **Inactive entities**: Organizations that were in existence before January 1, 2020, and meet specific inactivity criteria

HOA boards should consult with legal counsel to determine whether their association falls under one of these exemptions or must comply with the reporting requirements.

## Potential Consequences of Non-Compliance

The stakes for failing to comply with CTA requirements are significant. Non-compliance can result in:

– Civil penalties of up to $500 per day for continued violations
– Criminal penalties including fines up to $10,000
– Imprisonment for up to two years for willful violations

These potential consequences underscore the importance of timely compliance for HOAs subject to the reporting requirements.

## Steps for HOAs to Ensure Compliance

To meet the March 21, 2025 deadline, HOA boards should take the following actions:

1. **Consult legal counsel**: Work with an attorney familiar with both HOA operations and CTA requirements to determine your association’s reporting obligations
2. **Identify beneficial owners**: Determine which board members or officers qualify as beneficial owners under the CTA’s definition
3. **Gather required information**: Collect the necessary personal information from each beneficial owner
4. **Prepare for filing**: Set up a FinCEN account if needed and organize documentation
5. **Submit before the deadline**: Complete the BOI filing process through FinCEN’s online portal before March 21, 2025

## Ongoing Compliance Considerations

The CTA also imposes continuing obligations on HOAs after the initial filing. Associations must file updated reports within 30 days of any change in beneficial ownership information. This includes changes in board composition following annual elections or mid-term replacements.

HOA boards should establish processes to track these changes and ensure ongoing compliance with updating requirements.

## The Evolving Regulatory Landscape

It’s worth noting that the legal situation surrounding the CTA remains somewhat fluid. Additional court challenges or regulatory guidance could potentially alter compliance requirements or deadlines. HOAs should stay informed about developments that might affect their obligations under the Act.

## Conclusion

The reinstatement of the Corporate Transparency Act’s reporting requirements represents a significant compliance obligation for many HOAs across the country. With the March 21, 2025 deadline approaching, boards must act promptly to determine their association’s status under the Act and, if necessary, gather and submit the required beneficial ownership information.

By understanding these requirements and taking proactive steps toward compliance, HOA boards can avoid potential penalties while fulfilling their legal obligations under this important anti-money laundering and financial transparency legislation.

For the most current information on CTA requirements and deadlines, HOA boards should consult with qualified legal counsel and monitor updates from FinCEN as the March 2025 deadline approaches.