2026-09-10 · Indiana · Compliance

What happened. The two-year question of whether Indiana homeowners and condominium associations had to file beneficial-ownership reports with the federal government has closed. They do not, the obligation is gone rather than paused, and the litigation that was keeping the issue alive ended last week.

How it got here

The Corporate Transparency Act obliged “reporting companies” to disclose their beneficial owners to the Financial Crimes Enforcement Network. As originally written, that definition swept in ordinary nonprofit corporations — which is what nearly every Indiana association is — and put board members in the position of filing personal identifying information about themselves as a condition of volunteering.

In March 2025 FinCEN issued an interim final rule that narrowed the definition sharply. Its own summary of the effect:

“companies created in the United States are no longer considered reporting companies and therefore do not need to report BOI to FinCEN”¹

What made it permanent

An interim rule is by nature provisional, and many associations sensibly treated the reprieve as one. That changed on 14 August 2026, when FinCEN's final rule took effect. Treasury's statement of it is unambiguous: U.S. companies “are exempt from BOI reporting requirements and therefore, are no longer required to file BOI reports,” with “reporting company” now meaning only entities “formed under the law of a foreign country” and registered to do business in a U.S. state.²

Treasury also stated that FinCEN “will delete previously submitted information by U.S. persons” from its database — which reaches the Indiana board members who did file in 2024 and early 2025.

And the lawsuit ended

The Community Associations Institute sued Treasury in September 2024 seeking exactly this exemption for community associations. The case, No. 1:24-cv-01597 in the Eastern District of Virginia, was held in appellate abeyance from May 2025 while the rulemaking ran. On 9 September 2026 the parties' motion for voluntary dismissal was granted and the mandate issued.³

It ended because it had won on the merits elsewhere: the final rule gave the plaintiffs what the litigation was for.

1. FinCEN, Beneficial Ownership Information Reporting — interim final rule questions and answers (Mar. 26, 2025) ↩
2. U.S. Dep't of the Treasury, statement on the final beneficial-ownership reporting rule (Aug. 2026) ↩
3. Community Associations Institute v. U.S. Dep't of the Treasury, No. 1:24-cv-01597 (E.D. Va.) — docket (voluntary dismissal granted Sept. 9, 2026) ↩
4. 75 IAC 8 (LSA Doc. #25-155), Indiana Secretary of State business entity filing rule, final rule (filed May 19, 2025) ↩