Beginning January 1, 2024, the Corporate Transparency Act (“CTA”) requires many small businesses to report information about the association and individuals who exercise “substantial control” over the business. Most homeowner’s associations will also need to report.

These reports are filed online with the Treasury Department’s Financial Crime Enforcement Network (FinCEN). If your association was formed before January 1, 2024, you have until the end of 2024 to file. The reports must be updated when changes occur. Failing to report can result in criminal and civil penalties.

A homeowner association must report (1) the full name of the association, (2) all other names the HOA uses, (3) its business street address, (4) the jurisdiction of its formation, and (5) its IRS Taxpayer Identification Number, as well as (6) information about its beneficial owners. A beneficial owner is one who (a) owns or controls more than or equal to 25% of the association or (b) exercises “substantial control” over the association. This could include managers, officers, directors, and others.

The CTA requires that these beneficial owners report their (1) full name, (2) date of birth, (3) complete and current residential street address, and (4) a unique, identifying number from a non-expired passport, identification document or driver’s license and an image of the document. Individuals can obtain personal identification numbers by filing with FinCEN, which the HOA can then use in lieu of asking the individual for their information.

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