While independent parties continue to challenge the application of the CTA to condominium and homeowner associations, it still appears to apply. We recommend that associations hold off on its reporting requirements as we continue to obtain further clarity on the CTA as it seems to be an ever-evolving statute. To that, new guidelines for compliance were issued on April 18, 2024. This involves a nationwide database of beneficial ownership (i.e. board members, as board members exercise substantial control over reporting company/association). Further, a reporting company may provide a FinCEN identifier (“FinCEN ID”) instead of the beneficial owner’s personal information when filing. This allows board members to protect sensitive personal information and eliminates the need for an association to file an updated report when board members change. The deadline to comply is January 1, 2025.

If you have any questions, please reach out to one of our experienced HOA Attorneys: Kat Formeller at or Kathy Heitkemper at