The timeline, because the whiplash is the reason boards are confused

• 1 January 2025 — the original filing deadline, which Michigan associations spent 2024 preparing for. Volunteer directors' names, dates of birth, home addresses and identification images were to go to the federal government.
• Early 2025 — litigation, injunctions and repeated stays. Deadlines moved several times.
• 26 March 2025 — interim final rule exempting domestic entities.
• 14 August 2026 — final rule, permanent, scope widened to company applicants and FinCEN identifiers.

Three concrete things follow for a Michigan board. Retire the compliance calendar entry. Stop paying anyone for it — any management contract or vendor agreement still charging a “BOI filing fee” is charging for nothing. And if the association filed in 2024 or early 2025, there is nothing to correct and nothing to update, ever.

The rule that people keep confusing with this one, and it is live

FinCEN's Residential Real Estate Reporting Rule, 31 CFR § 1031.320, took effect 1 March 2026 — moved from 1 December 2025 by a temporary exemptive relief order announced 30 September 2025.² It applies to transfers closing on or after that date.

It requires a “reporting person” — a settlement agent, title insurer, closing attorney or other closing professional — to file a report with FinCEN for a non-financed transfer of residential real property to a legal entity or trust.

This one falls on the closing table, not on the association. But it touches a real slice of Michigan condominium sales: all-cash purchases of units into an LLC or a revocable trust, which is the standard vehicle for retiree buyers and small investors in Michigan condominium projects.

What the difference means for a board and a manager

• The association files nothing under either rule. Not the CTA rule, which is dead for domestic entities, and not the real-estate rule, which is the closing professional's obligation.
• Expect the request anyway. Boards approving transfers, and managers producing resale certificates, will see reporting-related enquiries at closing. Those come from the real-estate rule and are legitimate.
• Correct the confusion when it arises. A closing agent asking about a trust buyer is not evidence that the CTA is back.

Why this mattered more in Michigan than in some states

Because Michigan associations are unusually likely to be volunteer-run without professional management. The original CTA imposed personal-information reporting on individual unpaid directors, and Michigan association counsel reported it as a genuine deterrent to board service in small projects. That deterrent is gone.

What to watch next

Nothing on the CTA; the rule is final and the direction is settled. On the real-estate rule, watch whether FinCEN expands the categories of reporting person or the transfer types covered — that is the rule with room to move.