Corporate Transparency Act: Do HOAs Still Have to File?

Why HOAs Were Worried

The federal Corporate Transparency Act (CTA) originally required most domestic reporting companies to report their beneficial owners to FinCEN. Because most HOAs and condominium associations are incorporated nonprofits, many boards were told they might have to file, and that directors might have to submit personal identifying information.

What Changed

After a series of court decisions that alternately blocked and allowed enforcement, FinCEN issued an interim final rule on March 26, 2025 exempting all entities created in the United States from beneficial ownership reporting. As a result, a Michigan nonprofit corporation that operates as an HOA or condominium association is not currently required to report its directors' information.

What Boards Should Still Do

• Do not rely on this as permanent. The exemption comes from an agency rule, which could be revisited. Keep an eye on FinCEN guidance.
• Keep your corporate records current. Annual state filings, current registered agent information, and an up-to-date board roster still matter.
• Ask counsel about other federal rules. Separate real estate reporting requirements may touch certain property transactions; your association attorney can tell you whether anything applies to your community.

See also: Michigan HOA laws 2025-2026: what changed and fiduciary duty basics for board members.

APM provides full-service and remote community association management across Michigan. See our Michigan board and homeowner resources, the Michigan communities we serve, or contact APM to talk through how these changes affect your association.

Legal disclaimer: This article is general information, not legal advice. Statutes and effective dates can change; confirm details with a licensed Michigan attorney before acting.