The one condition that would change the answer

The exemption turns on where the entity was formed, not on what it does. A reporting company is now a foreign-formed entity registered to do business in a US state or tribal jurisdiction.

A Louisiana association organised under the Louisiana Nonprofit Corporation Law is domestic and therefore exempt. An association that was formed in another jurisdiction and registered to do business in Louisiana would need to look again — and note that “foreign” in this federal sense means formed outside the United States, not formed in another state. That combination is vanishingly rare for a residential community association, but it is the exception, so we state it rather than leaving a flat rule.

What to actually do with the documents you already produced

Two housekeeping points, both about association records rather than about FinCEN.

Take BOI off your records list. R.S. 9:1141.36(A) sets out eleven categories of association records a Louisiana planned-community association must retain. A beneficial-ownership filing is not among them, and there is no longer a filing to retain. An association that collected directors' identifying documents in 2024 in order to report them is holding personal data with no remaining purpose — and note that R.S. 9:1141.36(C)(1) permits withholding “[p]ersonnel and medical records relating to specific individuals” from inspection, which is a reason to segregate rather than to keep.

Correct the compliance calendar. Any Louisiana board handbook, management agreement or annual checklist still carrying a FinCEN deadline is wrong twice over — once for the March 2025 interim relief and again for the August 2026 final rule.

The state filing that does still exist, and does have teeth

Louisiana associations often conflate the federal filing with the state one. The state one is the annual report to the Secretary of State, and neglecting it has a consequence the federal filing never had.

R.S. 12:262.1 provides that where a corporation “has failed to designate and maintain a registered office and to designate and maintain a registered agent pursuant to the provisions of R.S. 12:236, for a period of one hundred eighty consecutive days, or where a corporation has failed to file an annual report for three consecutive years, according to the records of the secretary of state, the secretary of state shall revoke the articles of incorporation and franchise of such corporation.”

There is a warning first — “[a]t least thirty days prior to revoking … the secretary of state shall give notice to the affected corporation of his intention to revoke … by directing notice of such intention to the last designated registered agent” — and a cure: “C. The corporation shall not be revoked if the corporation places itself in good standing.” Reinstatement is available on application filed “within three years from the effective date of the revocation,” with a fee and a current annual report; after three years the corporate name is released for that period and may have to be changed.

This is not academic for a Louisiana association, because R.S. 9:1141.19 requires a lot owners association to be organised as a nonprofit corporation authorised to do business in Louisiana. Whether and how revocation affects a board's authority to act in the corporate name is a question we are not going to answer in the abstract — it depends on what was done and when — but it is a question no board wants to be asked.

The fees change on October 1, 2026. Under Act 921 of 2026, articles of incorporation for a Louisiana nonprofit go from $75 to $95, articles of reinstatement from $75 to $95, and a change of registered office or agent from $25 to $30. The nonprofit annual report stays at $10.³

What a board can do

• File the annual report every year, and check it filed. It costs $10 and its absence for three years costs the corporation.
• Keep the registered agent current. One hundred and eighty days without one is an independent ground for revocation, and the revocation warning goes to that same agent.
• Check the Commercial Database. It is free, it is public, and it is the one state record about a Louisiana association that any owner can read without going through the board.
• Ignore BOI solicitations. There is no filing, and the Secretary of State says not to report to anyone but FinCEN.

What to watch next

Nothing pending. Nothing in the 2025 or 2026 Louisiana sessions amended R.S. 12:262.1, and no Louisiana Register rule in the window changed revocation or reinstatement practice. The October 1, 2026 fee schedule is the only dated change on this file.