2026-09-10 · Georgia · Regulation

What happened. The question that filled Georgia board packets through 2024 — whether an association must report its directors to the federal government — now has a settled answer. It is no, permanently, and the data already filed is being deleted.

FinCEN's final rule, “Beneficial Ownership Information Reporting Requirement Revision,” RIN 1506-AB67, amending 31 C.F.R. part 1010, was announced 11 August 2026 and published and effective 14 August 2026.¹

Why this needs saying twice

Because the answer changed twice, and Georgia associations acted on all three versions.

• 2024 — the Corporate Transparency Act took effect. Community associations, as domestically formed nonprofit corporations, were widely advised that they were reporting companies and had to file beneficial ownership information identifying their board members. Many Georgia associations filed.
• 26 March 2025 — FinCEN issued an interim final rule narrowing “reporting company” to entities formed under foreign law and registered to do business in a US state or tribal jurisdiction, exempting all domestically formed entities.²
• 14 August 2026 — the final rule made that permanent, and went further.

What the rule now says

FinCEN's own guidance states the position flatly: “U.S. companies are exempt from the Beneficial Ownership Information (BOI) reporting requirements and therefore, are no longer required to file BOI reports,” and “U.S. persons do not need to provide BOI to reporting companies.”³

Per Treasury's announcement, the final rule also:

• exempts US persons holding FinCEN identifiers from updating previously reported information;
• removes the requirement that foreign companies report US-person company applicants;
• exempts foreign pooled investment vehicles from reporting US-person beneficial owners; and
• directs FinCEN to delete previously submitted information about US persons from its database.

That last item is the one aimed at Georgia boards. An association that filed in the brief 2024-25 compliance window is not merely being ignored — the data is being purged.

The bottom line for a Georgia association

A homeowners, condominium or property owners' association incorporated in Georgia has no Corporate Transparency Act filing obligation of any kind. No initial report, no updates, no corrections, no annual confirmation.

What remains is narrow: only foreign entities registered to do business in the United States, and not otherwise exempt, must file — and they report beneficial ownership only for foreign individuals.

1. Treasury announces final beneficial ownership rule, 11 August 2026 ↩
2. Treasury announces interim final rule narrowing BOI reporting, March 2025 ↩
3. Beneficial Ownership Information Reporting — FinCEN (current status) ↩
4. Senate Bill 406, as passed (26 LC 49 2879S) — signed copy, Office of the Governor ↩
5. How to File Annual Registration — Georgia Secretary of State ↩