2026-09-09 · Connecticut · Compliance

A Connecticut nonstock corporation that operates a condominium or homeowners association has no beneficial ownership reporting obligation, and its volunteer directors have none either. A final rule announced August 11, 2026 and effective August 14 permanently ends the requirement for entities created in the United States.¹

That closes a question that produced two years of conflicting advice to Connecticut boards.

How it got here

The Corporate Transparency Act required “reporting companies” to file beneficial ownership information with the Financial Crimes Enforcement Network. Community associations are typically incorporated — in Connecticut, usually as nonstock corporations — and nothing in the original framework clearly exempted them. Boards across the country were told they might have to report their directors’ personal details, with penalties for failure.

March 2025: FinCEN issued an interim final rule stating that “all entities created in the United States — including those previously known as ‘domestic reporting companies’ — and their beneficial owners will be exempt from the requirement to report BOI to FinCEN.”²

August 2026: the final rule made it permanent, and FinCEN said it will delete information previously submitted by filers now exempt.¹

What this means for a Connecticut board

Nothing to file. Nothing to update when directors change. Nothing to correct. And for associations that filed during the window when the obligation appeared to apply, the submitted information is to be deleted.

The distinction that matters is between the interim posture and the current one. Between March 2025 and August 2026 the exemption existed but rested on an interim rule issued during ongoing litigation, which is why cautious advice often stopped short of telling boards the question was closed. It is now a final rule.

1. FinCEN Permanently Ends Beneficial Ownership Reporting Requirements for Millions of Small Business Owners, U.S. Department of the Treasury (August 11, 2026; effective August 14, 2026) ↩
2. FinCEN Removes Beneficial Ownership Reporting Requirements for U.S. Companies and U.S. Persons, interim final rule (March 21, 2025) ↩
3. Public Act No. 26-31, § 1 — court-ordered audit of association financial records, effective October 1, 2026 ↩