Navigating CTA Compliance for Condos, Co-ops, and HOAs: Are You Ready?

With new Corporate Transparency Act (CTA) requirements impacting a wide range of entities, it’s essential for condos, co-ops, and HOAs to understand their obligations—or risk costly penalties. For many, compliance isn’t just about meeting deadlines; it’s about knowing who needs to be reported and staying up-to-date with changing regulations. Here’s what you need to know:?

Who is Exempt?? Certain condos, co-ops, and HOAs are exempt as “large operating companies” if they:?

• Employ 20+ full-time employees in the U.S.,?

• Operate from a physical office location within the U.S., and?

• Filed last year’s taxes showing $5 million+ in gross U.S. sales or receipts.?

Who Needs to Report?? For non-exempt entities, FinCEN requires reporting on all beneficial owners, defined as individuals who:?

1. Hold substantial control (e.g., senior officers or those with decision-making authority), or?
2. Own or control 25% or more of the organization.?

Typical Beneficial Owners for Co-ops, Condos, and HOAs generally include:?

• Senior officers and potentially board members,?

• Shareholders or unit owners with a 25%+ ownership interest, and?

• Sponsors who retain control or a significant ownership stake.?

Important Note on Board Members? FinCEN guidance clarifies that not every board member is automatically a beneficial owner. Each member’s role is reviewed individually based on their level of control. However, for New York-based co-ops, condos, and HOAs, it’s prudent to include all board members unless their control is clearly limited.?

Ongoing Reporting Requirements? An initial BOI report is required for all reporting companies, and any major updates—such as changes in senior officers—must be reported within 30 days.?

How FinCEN Advisors Can Help? At FinCEN Advisors, we specialize in helping associations like yours navigate the complexities of CTA reporting. Our team offers customized support to ensure compliance is smooth, accurate, and efficient. Reach out to us today to streamline your CTA obligations.?

#CTACompliance #HOA #CoopAssociations #CondoAssociations #FinCEN #BeneficialOwnership #ComplianceSupport?

?