FinCEN Ends BOI Reporting for Community Associations: What Maryland Boards Need to Know
- Jordan Fox
- 1 day ago
- 4 min read
On August 11, 2026, the U.S. Department of the Treasury's Financial Crimes Enforcement Network, commonly known as FinCEN, issued a final rule permanently removing beneficial ownership information reporting requirements for U.S. companies and U.S. persons under the Corporate Transparency Act.
For condominium associations, homeowners associations, and other community associations formed in the United States, the result is straightforward: the association is not required to file a beneficial ownership information report with FinCEN, and its volunteer board members are not required to provide personal information to FinCEN solely because of their service on the board.
The change eliminates a compliance concern that had caused uncertainty for community association boards across the country.
What Is Beneficial Ownership Information Reporting?
The Corporate Transparency Act created a federal reporting system intended to help law enforcement identify individuals who own or substantially control certain legal entities. Beneficial ownership information, often abbreviated as BOI, can include an individual's name, date of birth, address, and identifying document information.
Although the law was primarily intended to combat money laundering and the misuse of shell companies, many community associations were initially considered reporting companies. That interpretation raised concerns because associations generally do not have traditional owners. Instead, they are governed by homeowners who volunteer to serve as directors.
Under the original framework, those volunteer directors could have been treated as beneficial owners because of the authority they exercised on behalf of the association.
What Changed in BOI Reporting for Community Associations?
FinCEN first relieved U.S. companies and U.S. persons from BOI reporting through an interim final rule published in March 2025. The new final rule makes those regulatory exemptions permanent and expands certain protections for U.S. persons.
Under the final rule:
U.S.-formed companies, including domestic community associations, are exempt from BOI reporting.
U.S. persons, including community association board members, do not have to provide BOI to FinCEN.
U.S. persons who obtained a FinCEN identifier are no longer required to update or correct the information previously submitted for that identifier.
Certain entities formed under foreign law and registered to do business in the United States may still have reporting obligations, although they generally do not report information about U.S. persons.
The final rule becomes effective when it is published in the Federal Register. However, the March 2025 interim final rule is already in effect, so domestic community associations are not currently required to file BOI reports while awaiting that publication.
What Happens to Information That Was Already Submitted?
Some associations and board members submitted BOI reports before the domestic-company exemption took effect. FinCEN has announced that it is implementing a process to delete information it reasonably believes was provided by U.S. companies and U.S. persons who are now exempt.
FinCEN does not currently anticipate requiring associations or individuals to request deletion. It also does not plan to send individual confirmations when records are deleted. Instead, the agency expects to post a public notice on its website after completing the deletion process.
Associations should retain their own records showing what was filed and when, but board members should not submit updates or additional reports merely to request deletion unless FinCEN later issues different instructions.
Does This Repeal the Corporate Transparency Act?
No. The Corporate Transparency Act remains part of federal law. The Treasury Department and FinCEN have used their regulatory authority to exempt domestic companies and U.S. persons from the reporting requirements.
That distinction matters because Congress could amend or repeal the statute, and a future administration could potentially revisit the regulations through the federal rulemaking process. For now, however, the final rule establishes the controlling federal reporting framework.
What Should Maryland Association Boards Do Now?
For most Maryland condominium and homeowners associations, no new FinCEN filing is required. Boards and their management teams should:
Confirm that the association was formed under the laws of a U.S. state.
Remove unnecessary BOI filing or update deadlines from the association's compliance calendar.
Retain copies of any previously submitted reports with the association's restricted corporate records.
Avoid circulating board members' personal identifying information when there is no continuing business or legal need to do so.
Continue monitoring guidance from FinCEN, legal counsel, and community association industry organizations.
This change applies only to federal BOI reporting. It does not eliminate an association's other corporate, tax, banking, insurance, licensing, recordkeeping, or state-law obligations. Banks and other financial institutions may also continue requesting ownership or control information under separate customer due diligence requirements.
A Welcome Reduction in Administrative Burden
The final rule provides welcome clarity for community associations and their volunteer leaders. Board members should be able to serve their communities without being treated as the beneficial owners of an entity that has no conventional ownership structure.
For boards, the immediate action is simple: document the change, protect any information previously collected, and continue focusing on the association's actual governance and compliance responsibilities.
Frequently Asked Questions
Do Maryland condominium and homeowners associations still have to file BOI reports?
No. Associations formed under Maryland or another U.S. state’s laws are exempt from FinCEN’s beneficial ownership information reporting requirements.
Do community association board members have to provide their personal information to FinCEN?
No. U.S. persons, including volunteer association directors, are no longer required to report beneficial ownership information solely because they serve on an association’s board.
What if our association already submitted a BOI report?
FinCEN is developing a process to delete information previously reported by U.S. companies and U.S. persons. Associations are not currently expected to request deletion. However, they should retain a restricted internal record of any filing previously submitted.
Was the Corporate Transparency Act repealed?
No. The law remains in place, but FinCEN’s final rule exempts U.S. companies and U.S. persons from its BOI reporting requirements.
Related Resources for Association Boards
Selecting the right management partner affects far more than day-to-day administration. Read our guide on how to choose a community association management company to understand the experience, systems, and communication practices boards should evaluate.
For office, retail, industrial, and mixed-use condominium properties, see how to choose a commercial condominium management company for considerations specific to commercial associations.
JFI Real Estate Management works with condominium associations and community association boards throughout Maryland to strengthen financial reporting, vendor oversight, maintenance planning, governance support, and day-to-day administration. To learn more about our community association management services, contact JFI Real Estate Management.
This article is provided for general informational purposes and does not constitute legal or tax advice.
