2026-09-15 · Mississippi · Compliance

A Mississippi homeowners association incorporated under the Mississippi Nonprofit Corporation Act has nothing to file with FinCEN — no initial report, no updates, no change-of-director filings — and that is now a final rule rather than an interim one. The rule was published at 91 FR 52508 on August 14, 2026 and took effect the same day.¹

What the rule does

The March 2025 interim final rule (90 FR 13688) “revised the Reporting Rule by removing the requirements for domestic entities and U.S. persons to report BOI,” deleting the definition of “domestic reporting company” formerly at 31 CFR 1010.380(c)(1)(i).

The August 2026 rule adopts that as final and goes further. It adds a new 31 CFR 1010.380(b)(5), “Special exemptions,” exempting reporting companies from reporting the beneficial ownership information of any U.S.-person beneficial owners or company applicants, and exempting U.S. persons from having to provide it. It removes paragraph (d)(4) and exempts U.S. persons from updating FinCEN-identifier information.

Only entities formed under foreign law and registered to do business in a U.S. state remain “reporting companies” — and even those need not report U.S.-person beneficial owners. FinCEN received 118 comment letters on the interim rule and rejected narrower approaches.

1. FinCEN, "Beneficial Ownership Information Reporting Requirement Revision," final rule, 91 FR 52508 (Aug. 14, 2026) ↩
2. FinCEN interim final rule, 90 FR 13688 (Mar. 26, 2025) ↩