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ChihiroA (Virginia)
Posts: 1
Posted:
Just went to the FinCen site (https://fincen.gov/boi) and noticed the below notice was posted:

"[Updated March 21, 2025] All entities created in the United States — including those previously known as "domestic reporting companies" — and their beneficial owners are now exempt from the requirement to report beneficial ownership information (BOI) to FinCEN. Existing foreign companies that must report their beneficial ownership information have at least an additional 30 days from the date of publication of the interim final rule. For more information, see press release and alert."

Does this mean we no longer need to file a BOA to comply with the CTA since (I presume) my HOA is a "domestic reporting company"?
TimB4 (Tennessee)
Posts: 21,059
Posted:
From the summary of that rule:

SUMMARY: FinCEN is adopting this interim final rule to narrow the existing beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act
(CTA) to require only entities previously defined as “foreign reporting companies” to report BOI. Under this interim final rule, entities previously defined as “domestic reporting
companies” are exempted from the reporting requirements and do not have to report BOI to FinCEN, or update or correct BOI previously reported to FinCEN.
CathyA3 (Ohio)
Posts: 6,299
Posted:
Excellent news.

It's unfortunate that the government forced so many to spend time and money (particularly for lawsuits) and tied up the courts unnecessarily when FinCen could simply have directed their efforts toward places where money launderers and supporters of terrorism are likely to be hiding. This shouldn't have been so difficult.
MarshallT (New York)
Posts: 414
Posted:
You are correct. It's unfortunate that so much time and resources were wasted on this matter.
ElleN (Idaho)
Posts: 1,334
Posted:
Quote:
Posted By ChihiroA on 03/23/2025 10:39 AM

Does this mean we no longer need to file a BOA to comply with the CTA since (I presume) my HOA is a "domestic reporting company"?
It means that filing is on hold until further notice.

My understanding is that the Treasury Department is acting based on a recently passed bill of Congress. That bill did //not// eliminate the requirement to file. The bill delayed the deadline to file so Congress has a change to re-think its law and perhaps let the various lawsuits winding their way through the courts reach some resolution.
CathyA3 (Ohio)
Posts: 6,299
Posted:
The law is still on the books. But the recent change is more substantive than simply delaying the requirement to file. Per CAI's website:

CTA NATIONAL UPDATE: Corporate Transparency Act Suspended for Domestic Reporting Companies

Updated March 21, 2025, 6 PM EST

On March 21, Financial Crimes Enforcement Network (FinCEN) issued an interim final rule removing the requirement for U.S. companies and U.S. persons to report beneficial ownership information (BOI) to FinCEN under the Corporate Transparency Act. This is consistent with the U.S. Department of the Treasury’s March 2, 2025 announcement suspending enforcement of the Corporate Transparency Act against U.S. citizens and domestic reporting companies.

Under the interim final rule, FinCEN revises the definition of “reporting company” in its implementing regulations to mean only those entities that are formed under the law of a foreign country and that have registered to do business in any U.S. State or Tribal jurisdiction by the filing of a document with a secretary of state or similar office (formerly known as “foreign reporting companies”). FinCEN also exempts entities previously known as “domestic reporting companies” from BOI reporting requirements.


If you want to really get irked, you might want to read this legal filing (related to CAI's lawsuit against the Treasury). Pay close attention to section II that discusses Fourth Amendment issues.

ElleN (Idaho)
Posts: 1,334
Posted:
Quote:
Posted By CathyA3 on 03/24/2025 9:18 AM

Under the interim final rule
I think "interim" is the key word.
JackS20 (North Carolina)
Posts: 271
Posted:
so much drama about uploading yoru driver's license, lol.

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