BOI Reporting Requirements Under Corporate Transparency Act Officially End for Condominium Associations

BOI Reporting Requirements Under Corporate Transparency Act Officially End for Condominium Associations

The federal government has made a major change to beneficial ownership information (BOI) reporting; one that should simplify compliance for many condominium and homeowners associations.

On August 11, 2026, the U.S. Department of the Treasury announced that the Financial Crimes Enforcement Network (FinCEN) has finalized a rule eliminating BOI reporting requirements for U.S.-formed companies and U.S. persons.

What Does This Mean for Condo Associations? BOI reporting was created under the Corporate Transparency Act to provide the federal government with information about individuals who own or control certain businesses.

The requirements created questions for condo and HOA boards because many associations are organized as corporations or LLCs. Boards and managers had to determine whether they needed to report information about directors, officers, or other individuals involved in the association.

Under the new rule, U.S.-formed companies are exempt from BOI reporting. 

For a typical domestic condominium or homeowners association, this means the association generally does not need to file a BOI report with FinCEN. 

What If Your Association Already Filed? If your association previously submitted BOI information, FinCEN says it will delete information associated with U.S. persons who are now exempt from reporting.

Associations should still maintain their normal corporate records, including board rosters, meeting minutes, state filings, tax documents, and other records required under Illinois law and their governing documents.

It's also worth being cautious of unsolicited emails or invoices asking your association to pay a fee or provide personal information for BOI compliance.

What Should Your Board Do? While there is no new BOI filing requirement for most domestic associations, boards should:

  • Confirm your association's legal structure and state of formation.
  • Keep required corporate and association records up to date.
  • Be cautious of BOI-related scams or unsolicited filing requests.
  • Continue complying with Illinois condominium and corporate requirements.
  • Consult your association attorney if your entity has an unusual or foreign ownership structure.

For most Chicago-area condominium associations organized in the United States, the elimination of BOI reporting removes one more administrative burden from an already lengthy list of board responsibilities.

However, the change does not eliminate other federal, state, or local compliance requirements. Boards should continue to stay current on Illinois condominium laws, corporate filings, taxes, insurance, reserves, and other association obligations. 

Source: U.S. Department of the Treasury, August 11, 2026.