What an Indiana board can actually do

The answer for the overwhelming majority is nothing, and the useful work is confirming you are in that majority rather than acting.

• Confirm the entity is domestic. An Indiana association incorporated with the Indiana Secretary of State is formed under Indiana law. That is the whole test. The exemption is categorical — it does not depend on unit count, budget size, revenue, or whether the association is professionally managed.
• Stop any filing calendar you built in 2024. Some Indiana management companies added a BOI item to their annual compliance cycle, and a handful of governing-document amendments and management agreements from that period reference the obligation. Those references are now describing a rule that does not exist.
• Do not file protectively. There is nothing to be gained by submitting information to a system that is deleting the information it already holds from U.S. persons.
• Retain what you filed. Keep the association's own copy of any 2024–25 submission in the corporate record. FinCEN deleting its copy is not a reason for the association to lose its own audit trail of what was reported and by whom.

The obligation that did not go away

This is the part worth spending a board meeting on, because the relief has a way of blurring into a general sense that entity paperwork no longer matters.

Indiana associations remain nonprofit corporations with live state filing duties. The Secretary of State requires a periodic business entity report, and an association that stops filing it is administratively dissolved — which is a genuine problem, not a technicality. A dissolved association's standing to enforce covenants, levy assessments and bring suit becomes contestable, and the defect usually surfaces at the worst moment, in the middle of a collection action or at a closing.

The Secretary of State codified its electronic-filing surcharges in a rule that took effect in June 2025, and the nonprofit rates are modest: a $10 enhanced-access charge on electronically filing articles of incorporation, against $20 for entities generally, and $11 on a biennial report. The rule stated plainly that “These are not new fees nor new rejection reasons but are simply the promulgation in rule of already established existing fees.”⁴

So the sequence for an Indiana board this autumn is: drop the federal filing, verify the state one. The second is cheap, and it is the one with consequences.

Why the reversal happened at all

Worth understanding, because it explains how durable this is. The exemption was not a carve-out for community associations specifically — associations were never singled out for relief. FinCEN redrew the definition of “reporting company” around a domestic/foreign line, and every domestic entity fell outside it at once. Associations are beneficiaries of a much broader rewrite.

That breadth cuts both ways for planning purposes. It makes a narrow, association-targeted reversal unlikely. It also means any future change would arrive as a wholesale redefinition rather than as something an association-sector newsletter would flag early.

What to watch

The rule is in force and the litigation is closed, so there is no live proceeding to track. The residual questions are legislative: the Corporate Transparency Act remains on the statute books, and a future Congress could legislate a definition that the current rule cannot narrow. Nothing pending suggests that is imminent.

One caution on sourcing. We confirmed the substance through FinCEN's and Treasury's own published statements. We were not able to open the Federal Register page itself, so readers who need the precise Federal Register citation for a formal memorandum should pull it directly rather than take ours.