2026-09-12 · Michigan · Regulation

What happened. The Financial Crimes Enforcement Network issued a final rule, published and effective 14 August 2026, that permanently ends beneficial ownership information reporting for entities created in the United States. Beneficial Ownership Information Reporting Requirement Revision, document 2026-16576, RIN 1506-AB67.¹

A Michigan condominium or homeowners association incorporated under the Michigan Nonprofit Corporation Act is a domestic entity. It has no filing obligation — current, future, or corrective.

What the rule does

It adopts as final, with limited changes, the interim final rule of 26 March 2025. Specifically it:

• exempts reporting companies from reporting the beneficial ownership information of US person beneficial owners, and exempts those persons from providing it;
• additionally exempts reporting companies from submitting information about US person company applicants, and exempts those applicants from providing it;
• exempts all US persons from updating information already provided in connection with a FinCEN identifier.

“Reporting companies” are now, in effect, entities formed under foreign law that have registered to do business in a US state or tribal jurisdiction. FinCEN has said it will delete previously reported information submitted by now-exempt US persons.

1. FinCEN, “FinCEN Permanently Ends Beneficial Ownership Reporting Requirements for Millions,” 11 August 2026 ↩
2. FinCEN, postponement of the Residential Real Estate Reporting Rule to 1 March 2026 ↩
3. Federal Register record, Beneficial Ownership Information Reporting Requirement Revision (document 2026-16576, RIN 1506-AB67) ↩