FinCEN reporting requirements

We received a brochure back from our Secretary of State's office when we filed our annual business registration. The brochure states that we may have to report information about beneficial owners to the US Dept of Treasury's Financial Crimes Enforcement Network (FinCEN) under the Corporate Transparency Act passed by Congress in 2021. I quickly looked at the site and don't think we need to do this but I also don't see HOA's listed under exemptions. Anyone know about this?

The consensus I've seen from lawyers is that while community associations were probably not the intended targets of the Corporate Transparency Act, the language of the law does describe these entities. Therefore, many lawyers have been recommending to their clients to comply with the law since the penalties for failure to do so can be unpleasant (fines and jail time). And keep up with the news in case The People In Charge issue guidance saying that community associations do NOT need to submit their info. We have until the end of 2024 to file the information with the appropriate governmental agency.

Some of us have opined that these filing requirements may further discourage homeowners from serving on their boards, which is a problem most of us don't need.

Here is an article by a law firm:

What Board Members Should Know About the Corporate Transparency Act