Thursday, February 1, 2024

Update on Federal Corporate Transparency Act (“CTA”) for Condo Associations

 Mark S. Einhorn                         

There has been a lot of discussion regarding the filing requirements for community associations under the newly adopted CTA regulations in the news

lately.  Some associations have asked whether they should rush to file the Beneficial Ownership Information Report now or wait until the latter part of this year.

 For now, our best advice is to stay tuned and revisit the issue toward the later part of the year. There is no rush to file right now, but the consensus among professionals across the country is the CTA does apply to community associations.

 There are a few reasons we believe it is more prudent to wait.   First, associations in existence before January 1, 2024, have to report by January 1, 2025.  There is federal legislation pending that seeks to extend the deadline to file until 2026. It is very possible that the extension may be adopted, in which case no filing will be needed until that date.

 In addition, under the requirements, an association has to report every time there is a change of the board members.  So, if associations file now, they probably will need to file again, especially if an annual meeting will be held before the end of this year.  Lastly, Community Associations Institute (“CAI”) is also working to exempt condominiums from the requirements.  

 Mark is a partner at Marcus Errico Emmer & Brooks PC, concentrating his practice on transactional and condominium law. He can be contacted at