2026-09-10 · Massachusetts · Compliance

What happened. The multi-year worry that Massachusetts condominium trusts and homeowners associations would have to file beneficial ownership reports naming their volunteer board members is over, permanently.

FinCEN announced a final rule on 11 August 2026, effective 14 August 2026, adopting without substantive change the interim final rule it had issued on 26 March 2025. The relief for domestic reporting companies is now permanent.¹

What the rule does

• Domestic reporting companies are exempt from reporting beneficial ownership information for U.S.-person beneficial owners and company applicants
• Those U.S. persons need not provide their information
• Nobody must update or correct information previously submitted in connection with a FinCEN identifier

Essentially every Massachusetts condominium association and homeowners association falls in the exempt class.

What survives

The carve-out that remains is for “foreign reporting companies” — entities formed under foreign law and registered to do business in a U.S. state. That does not reach ordinary Massachusetts associations.

If you filed in early 2025

Boards that filed during the window when the requirement appeared to apply have no continuing update obligation. Nothing further is required.

1. FinCEN, news release: permanent end to beneficial ownership reporting requirements ↩
2. Secretary of the Commonwealth, voluntary association and certain trust filings (M.G.L. c. 182 §12) ↩
3. Greenberg Traurig, analysis of the August 2026 FinCEN final rule ↩