Three stale items to clear out

The reporting duty is gone; the cost of having prepared for it often is not. Worth checking:

• Vendor and law-firm subscriptions. Any Montana association still paying for CTA or BOI monitoring, filing services, or an annual “beneficial ownership compliance” line should stop. There is nothing to monitor.
• The board packet and the annual calendar. A standing agenda item or checklist entry for BOI updates on director turnover is now noise, and the kind of noise that makes a new board member think there is an obligation.
• The management agreement. Agreements signed in 2024 sometimes allocate CTA compliance to the manager, occasionally with a fee attached. That obligation has no subject matter now.

Why this one was a real scare and worth closing properly

The Corporate Transparency Act reached Montana associations by accident rather than design. Most are small nonprofit corporations formed under Title 35, chapter 2 — entities with volunteer directors, no employees, and no reporting infrastructure — and the Act's definition of a reporting company swept them in while its exemptions, built for regulated industries and large operating companies, largely did not reach them. The 30-day update requirement on changes to beneficial owners meant that in an association where the board turns over annually, the filing was a recurring duty with a penalty attached.

That is now resolved by the broadest possible route: not a carve-out for associations, which could be narrowed, but the removal of the entire domestic category. The operative fact does not depend on FinCEN's reasoning about associations at all — no US entity reports.

What is still true about association transparency in Montana

It is worth separating the federal retreat from the state position, because they are unrelated and a board could easily read the first as saying something about the second.

Montana has no statutory records-inspection right for association members, no duty to produce or distribute a budget or financial report, and no HOA registry, ombudsman or regulator of any kind. The 2025 bill that would have created financial-reporting duties, House Bill 232, died at the transmittal deadline. So an association's transparency obligations are whatever its declaration and bylaws impose, and nothing more.

That may change. The committee draft of a Uniform Common Interest Ownership Act now before the Local Government Interim Committee promises, in its own title clause, to establish “FINANCIAL AND OTHER ASSOCIATION RECORD CREATION AND RETENTION RULES” and “PROTECTIONS FOR PURCHASERS.” The committee takes executive action on it on September 17, 2026. If anything replaces the compliance burden the Corporate Transparency Act briefly imposed, it will come from Helena rather than Washington.

A sourcing note

We verified the status, the dates and the effect from FinCEN's own beneficial ownership information page. We did not open the Federal Register documents themselves, so we carry no Federal Register citation numbers for the interim final rule or the final rule, and we will not manufacture one. The dates above — March 26, 2025; August 11, 2026; effective August 14, 2026 — are as FinCEN states them.²