2026-09-12 · Maryland · Compliance

What happened. Beneficial-ownership reporting under the Corporate Transparency Act is over for Maryland community associations and their board members. The Treasury Department's Financial Crimes Enforcement Network published a final rule — FR Doc. 2026-16576, amending 31 C.F.R. § 1010.380 — effective 14 August 2026.¹

The rule exempts reporting companies from reporting US-person beneficial owners and US-person company applicants, and exempts US persons from providing that information or updating it. FinCEN has also said it will delete previously reported US-person information from its database.¹

For an incorporated Maryland condominium, homeowners association or housing cooperative, and for the volunteers who sit on its board, this closes a question that consumed three years of client alerts and board-meeting agenda time.

What this means concretely

• No filing. A Maryland association formed in Maryland has no beneficial-ownership reporting obligation.
• No updates. A board member who previously obtained a FinCEN identifier has no duty to update or correct the information supplied for it.
• No retention problem. Information already reported is being removed rather than merely left unused.
• The statute survives. The Corporate Transparency Act remains federal law. What changed is the implementing regulation, which now imposes no reporting duty on US-created entities or US persons.

The direction was already clear before the final rule: an interim final rule of 26 March 2025 redefined “reporting company” to cover only foreign-formed entities, which in practice exempted every US-created association from that point. The August 2026 rule makes it permanent.¹

1. Financial Crimes Enforcement Network, Beneficial Ownership Information Reporting Requirement Revision, FR Doc. 2026-16576, 31 C.F.R. § 1010.380, effective 14 August 2026 — exempting US-person beneficial owners and company applicants, with deletion of previously reported US-person information ↩
2. U.S. Department of Housing and Urban Development, Single Family Insurance — Condominiums: FHA Connection case-number assignment for Single-Unit Approval from 26 May 2026, with HUD's caveat that the change does not expand FHA's condominium programme ↩