In a unanimous decision on Dec. 16, the U.S. Court of Appeals for the 11th Circuit reversed and remanded a lower court’s stay of the Corporate Transparency Act in Nat’l Small Bus. United v. Dep’t of Treasury. This decision lifts the order blocking enforcement of the act issued by a district court in March 2024 that paused all reporting requirements for associations.
Despite the court ruling, community associations can continue to ignore the Corporate Transparency Act’s requirements to report beneficial ownership information to the Treasury Department’s Financial Crimes Enforcement Network. In March, FinCEN issued an interim final rule that removed reporting requirements for U.S. companies and persons.
Under the rule, FinCEN revised the definition of its regulations to mean only those entities formed under the law of a foreign country and registered to do business in the U.S. must submit ownership information. FinCEN also exempted entities previously known as domestic reporting companies.
CAI is waiting for the Treasury Department to publish a final rule but will continue to closely follow the National Small Business Association court case.
>>Read more about the Corporate Transparency Act.
At the COA where I am on the Board, I have seen other Board members use the lack of disclosure which this provides, to purchase other B units in foreclosure. Does CAI have a lobbyist arm? If so, what will be their legislative goals for 2026. I was hoping to see CAI get more involved in lobbying for their membership. Thank you.