The three things to actually change

1. Take CTA compliance out of the budget and the management agreement. Some Hawaii management contracts and board policies still carry a line item for beneficial ownership filings, or a fee for preparing them. That work no longer exists, and the fee should not survive it.

2. Tell directors their information is slated for deletion. Board members who filed personal identifying information — name, date of birth, address, an image of a driver’s licence or passport — did so reluctantly in many cases. FinCEN has said it will delete what U.S. persons reported. Directors are entitled to know that.

3. Stop treating a board election as a federal filing trigger. The compliance calendar item is retired.

What does not change

Everything the state requires. The Corporate Transparency Act was a federal beneficial-ownership register; Hawaii’s own registration and disclosure duties are untouched and are the ones with teeth:

• HRS § 514B-103 — biennial association registration with the Real Estate Commission, terminating June 30 of each odd-numbered year, for any project or association with more than five units. An association that fails to register “shall not have standing to maintain any action or proceeding in the courts of this State until it registers.”
• HRS § 514B-72 — the condominium education trust fund fee, with a ten per cent penalty for late payment and a bar on bringing any action to collect or foreclose until it is paid.
• HAR ch. 16-119.8 — the new registration rules effective March 26, 2026, under which failure to show continuous fidelity bond coverage through a registration period automatically terminates the registration.
• HRS § 514B-132 — managing agent registration, on a different biennium ending December 31 of an even-numbered year.

Those are the filings that can actually stop an association from collecting a delinquent assessment. The federal one never could.

A note on how this played out

The Corporate Transparency Act consumed a genuinely disproportionate amount of small-association attention between 2024 and 2026 — deadlines that moved, injunctions that came and went, and guidance that changed direction more than once. Volunteer boards spent real money on advice about it.

The instructive part is the pattern rather than the outcome: an obligation aimed at shell companies swept in tens of thousands of volunteer-run nonprofits because the definition of “reporting company” was drawn by entity form rather than by function. A board reading the next federal small-entity mandate should ask that question first — does this reach us because of what we do, or because of how we are incorporated?

What to watch

Whether any state creates its own beneficial ownership register that reaches nonprofit corporations. Several have considered it. Nothing of the kind is pending in Hawaii.