2026-09-10 · Idaho · Compliance

What happened. The Financial Crimes Enforcement Network issued a final rule on 11 August 2026, published in the Federal Register on 14 August 2026 and effective the same day, that permanently removes beneficial ownership information reporting under the Corporate Transparency Act for entities created in the United States.¹²

“Reporting company” is now defined to reach only entities formed under foreign law and registered to do business in the United States. An Idaho homeowners or condominium association incorporated under the Idaho Nonprofit Corporation Act is not one, and has no BOI filing obligation of any kind — initial, updated or corrected.

For association boards this closes a file that was open, contested and genuinely alarming for about eighteen months.

Why associations were ever in scope

The Corporate Transparency Act required a “reporting company” to file the identity of each beneficial owner — broadly, anyone exercising substantial control — with FinCEN. Community associations are usually incorporated non-profits, and none of the Act's twenty-three exemptions was drafted with them in mind. The widely followed reading was that most associations were reporting companies and that each director was a beneficial owner by virtue of substantial control.³

That produced a real compliance burden for volunteer boards: collecting an identifying document from every director, filing within the deadline, and re-filing within thirty days of any change — and association boards change every year.

How it unwound

The original first-report deadline for existing entities was 1 January 2025. Litigation and successive injunctions moved it repeatedly. On 26 March 2025 FinCEN issued an interim final rule that exempted all U.S.-formed entities, condominium and homeowners associations included, by redefining “reporting company” to cover only foreign entities.⁴

An interim final rule, however, is interim. The August 2026 action is the final rule that makes the change permanent.

1. Beneficial Ownership Information Reporting Requirement Revision, 2026-16576 (Fed. Reg., 14 Aug. 2026) ↩
2. U.S. Treasury, "FinCEN Permanently Ends Beneficial Ownership Reporting Requirements for Millions of Small Business Owners" (11 Aug. 2026) ↩
3. FinCEN news release on the final rule ↩
4. FinCEN, Beneficial Ownership Information Reporting (current guidance and interim final rule history) ↩