The U.S. Treasury Department’s Financial Crimes Enforcement Network issued its long-awaited final rule on Aug. 11, removing requirements for U.S. companies and persons, including community association board members, to report beneficial ownership information under the Corporate Transparency Act. The final rule is effective pending publication in the Federal Register.
FinCEN also announced it will delete previously reported information by people who disclosed personal information to the department from its database. Last year, FinCEN issued an interim final rule removing reporting requirements for U.S. companies and persons.
CAI has strongly advocated to relieve community association board members from the Corporate Transparency Act’s reporting requirements because the controversial law raised significant compliance and privacy concerns for associations and volunteer leaders.
In 2024, CAI filed a federal lawsuit against the Treasury Department. The suit challenged the application of the act to community associations, arguing volunteer leaders were unintentionally caught within a law intended to combat money laundering and other illicit financial activity.
Under the final rule:
- U.S. companies and U.S. persons, including community association board members, are permanently exempt from beneficial ownership reporting requirements.
- U.S. persons who obtained FinCEN identifiers are not required to update or correct information previously provided.
- FinCEN will implement a process to delete previously reported information provided by U.S. persons, including information submitted by community association board members.
- Certain foreign entities registered to do business in the United States remain subject to reporting requirements.
These changes do not constitute a repeal of the act; the final rule alters how the law is applied in practice. The statute remains law unless Congress explicitly repeals it.
In 2025, Ohio Rep. Warren Davidson introduced H.R. 425 – Repealing Big Brother Overreach Act. If passed, it would fully repeal the act and require FinCEN to delete data filed by individuals and entities within 90 days of the bill’s adoption. The bill was approved in April by the House Financial Services Committee and will be sent to the House floor for consideration. CAI continues to urge members to contact their representatives and advocate that they support H.R. 425.
>>For more information on the Corporate Transparency Act, visit www.caionline.org/cta.
