2026-09-12 · Missouri · Compliance

What happened. The U.S. Treasury permanently ended beneficial-ownership reporting for domestic companies. A final rule published and effective 14 August 2026 exempts United States persons and domestic entities from the Corporate Transparency Act reporting requirements. For a Missouri homeowners or condominium association incorporated under Chapter 355, there is no report to file, no update obligation and no correction obligation — permanently, by rule, not by a litigation stay.¹

The document is “Beneficial Ownership Information Reporting Requirement Revision,” 91 FR 52508, RIN 1506-AB67, signed by FinCEN Director Andrea M. Gacki. Its DATES caption reads: “This rule is effective August 14, 2026.” It amends 31 C.F.R. § 1010.380.

The exemption, quoted in full

“(5) Special exemptions. (i) Reporting companies are exempt from any requirement under 31 U.S.C. 5336 and this section to report the beneficial ownership information of any United States persons who are beneficial owners or company applicants.

(ii) United States persons are exempt from any requirement under 31 U.S.C. 5336 and this section to provide beneficial ownership information with respect to any reporting company for which they are beneficial owners or company applicants.”

And on the domestic-entity exclusion it makes final:

“First, the IFR exempted all entities previously defined as 'domestic reporting companies' from the requirement to file initial BOI reports or to update or correct previously filed BOI reports. The IFR did so by excluding all domestic entities from 31 CFR 1010.380's definition of 'reporting company'…”

From the rule's own abstract: “FinCEN is issuing this final rule to adopt as final and with certain limited changes the interim final rule issued on March 26, 2025, which narrowed beneficial ownership information (BOI) reporting requirements under FinCEN's regulations implementing the Corporate Transparency Act (CTA).”

Why a Missouri association is inside the exemption

A Missouri homeowners association, condominium association or incorporated subdivision trustee body comes into existence by filing with the Missouri Secretary of State — typically as a not-for-profit corporation under Chapter 355, RSMo. That makes it a domestic entity, and the final rule puts all domestic entities outside the definition of “reporting company.”

The corollary matters as much: board members are not reportable individuals. Missouri volunteer trustees who were told in 2024 to hand a driver's licence image to their management company for a federal filing have no such obligation and never will under this rule.

What happens to data already filed

“To facilitate the deletion of U.S. person information from the BO IT System that is no longer required to be reported, FinCEN expects to rely upon information provided in previously filed BOIRs to identify all domestic reporting companies, company applicants, and beneficial owners associated with domestic reporting companies.”

“At this time, FinCEN does not anticipate requiring or requesting that U.S. companies or U.S. persons contact FinCEN requesting that their BOI be removed. Additionally, FinCEN does not intend to provide any acknowledgement or confirmation of the deletion of a U.S. company or U.S. person's BOI. FinCEN will provide notice to the public on its website when it has completed the deletion process.”

So an association that filed in 2024 should expect its information to be deleted, should not expect a receipt, and should not write to FinCEN asking for one.

1. FinCEN, “Beneficial Ownership Information Reporting Requirement Revision,” final rule, 91 FR 52508 (Aug. 14, 2026) ↩
2. FinCEN news release announcing the permanent end of beneficial-ownership reporting ↩
3. Mo. Rev. Stat. ch. 355 (Revisor of Statutes) — Missouri nonprofit corporation law, including the annual registration report and § 355.706 ↩