2026-09-10 · Hawaii · Compliance

Two years of on-again, off-again Corporate Transparency Act obligations for Hawaii association boards are over. A FinCEN final rule issued August 11, 2026 and effective August 14, 2026 removes beneficial ownership information reporting for U.S. companies and U.S. persons.¹²

What the rule does

• Reporting companies are exempted from reporting BOI of U.S.-person beneficial owners.
• U.S.-person beneficial owners are exempted from providing it.
• Reporting companies need not submit information about U.S.-person company applicants.
• FinCEN has said it will delete previously reported information from U.S. persons from the BOI database.

Why associations were caught in the first place

Most Hawaii condominium and planned community associations are incorporated nonprofits under HRS ch. 414D. That made them arguably “reporting companies” under the Corporate Transparency Act, with directors as beneficial owners — meaning every board election was potentially a triggering event requiring an updated filing within a short window, with penalty exposure for missing it.

That is now gone. No filing, no updating obligation for director turnover, no penalty exposure.

1. FinCEN final rule, “Beneficial Ownership Information Reporting Requirement Revision,” Federal Register, August 14, 2026 ↩
2. U.S. Department of the Treasury, “FinCEN Permanently Ends Beneficial Ownership Reporting Requirements for Millions of Small Business Owners” ↩
3. HRS § 514B-103, Association registration ↩