HOA Boards Must File BOIR–FinCEN ID Registration Required for Board Members

Important Update: Corporate Transparency Act – FinCEN Registration 

Dear Community Members, 

We have an important update regarding the Corporate Transparency Act (CTA) and its implications for our community associations. Late on December 23rd, the Fifth Circuit Court of Appeals granted a stay over the injunction issued by the U.S. District Court for the Eastern District of Texas earlier this month. This court order reinstates the beneficial ownership information filing requirements (BOIR) under the CTA for all community associations, with a new deadline extended to January 13. 

What This Means for You as a Board Member 

As a board member, it is crucial to understand and act upon the following requirements: 

  1. Register and Secure a FinCEN ID
  1. You must obtain a FinCEN ID number before The Summit can file the Beneficial Ownership Information Report (BOIR) on behalf of the HOA. 
  1. If you have already registered and forwarded your FinCEN ID to The Summit, no further action is required. 
  1. If you have not registered, you must do so immediately and forward your FinCEN ID to The Summit to ensure we can file the BOIR report by December 31. 
  1. Penalties for Non-Compliance
  1. Failing to register for a BOIR can result in civil penalties of up to $591 per day. 
  1. There are also potential criminal penalties, including fines of up to $10,000 and/or imprisonment for up to two years for willful non-compliance or providing false information. 

How to Register 

To create your account and secure your FinCEN ID, please use the following official government link:  

https://fincenid.fincen.gov/landing

 Registration is free. 

Beware of Third-Party Services 

It has come to our attention that several online companies are offering FinCEN ID and BOIR registration services for a fee. We strongly advise against dealing with these entities. The registration process is straightforward and free through the official government website. 

Final Thoughts 

We understand that these requirements may seem daunting, but compliance is essential to avoid significant penalties. If you have any questions or need assistance with the registration process, please do not hesitate to contact us.