2026-09-15 · Montana · Compliance

What happened. The federal filing requirement that alarmed association boards through 2024 is permanently gone for US entities. A Montana HOA or condominium association has no beneficial ownership information filing obligation.

The sequence

FinCEN's interim final rule of March 26, 2025 removed the requirement for US companies and US persons to report beneficial ownership information under the Corporate Transparency Act. The final rule was published in the Federal Register on August 11, 2026 and became effective August 14, 2026, making the exemption for US entities permanent and extending relief to US persons.¹

Under the final rule, “domestic reporting companies” no longer exist as a category subject to reporting. Only foreign entities registered to do business in the United States must file, and they need not report US persons as beneficial owners.

FinCEN's own position is that the broad exemption eliminates the need for separate carve-outs for specific US entity types, homeowners associations included. Its beneficial ownership information page now states flatly that “U.S. companies are exempt from the Beneficial Ownership Information (BOI) reporting requirements.”

What this removes, concretely

• No initial report.
• No 30-day update when directors turn over — the duty that would have bitten hardest, given how often association boards change.
• No penalty exposure.

1. Beneficial Ownership Information — Financial Crimes Enforcement Network, U.S. Department of the Treasury (stating that U.S. companies are exempt from BOI reporting) ↩
2. Local Government Interim Committee — HJ 50 study materials and the UCIOA committee draft, including its record creation and retention provisions ↩