On February 18, 2025, the last remaining injunction against the CTA was lifted. This decision reinstates the Beneficial Ownership Information (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The CTA, as originally enacted, applies to most community, subdivision, and condominium associations, as well numerous other entities, by requiring them to disclose their beneficial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. We will continue to monitor these developments and will provide updates as needed. Given how quickly things are evolving as we lead into a new deadline, this ruling might not be the last word on the CTA.
Reprinted with permission from MAGWV, PLLC – Condominium & HOA Lawyers, Michigan