Stop paying for compliance monitoring

Many Ohio associations paid a management company, a law firm or a filing service in 2024 to file BOI reports naming every board member, with images of their driver's licences. Some of those arrangements were sold as ongoing services — annual updates, change-of-director filings, compliance monitoring.

Those obligations are gone permanently. An association still paying a recurring fee for Corporate Transparency Act compliance is paying for nothing, and the line item should come out of the next budget. Our Ohio director qualifications page covers what a board member's actual disclosure obligations are.

The one date still on the calendar

FinCEN intends to delete previously filed information about U.S. persons, but the process has three features that matter to an association.

It is automatic: “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.”

It is unacknowledged: “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.”

And it happens once: “To accomplish this deletion efficiently, FinCEN anticipates undertaking the project in one sweep of the database, not as a regular, periodic sweep…FinCEN only intends to complete this process one time. If BOI relating to a U.S. company or a U.S. person is included—inadvertently or intentionally—in a filing made after February 10, 2027, FinCEN does not anticipate deleting that information.”

February 10, 2027. Anything filed after that date stays. For an association whose directors' identity documents were uploaded in 2024, the practical instruction is simple: do not file anything else, and do not let a vendor file anything else on the association's behalf.

Two other federal items Ohio boards are getting wrong

The ADA website rule does not apply to you. Vendors have been selling Ohio associations website-accessibility remediation on the strength of “the new ADA website rule.” That rule — 28 CFR part 35, adopting WCAG 2.1 Level AA — implements Title II of the ADA and binds state and local government entities. An Ohio association organised under R.C. chapter 1702 or 5311 is not a public entity and is not covered by it.

Its deadlines moved anyway. An interim final rule at 91 FR 20902, effective April 20, 2026, extended compliance for public entities of 50,000 or more from April 24, 2026 to April 26, 2027, and for smaller entities and special districts to April 26, 2028.

The real exposure runs through Title III, where DOJ has never issued a web-accessibility regulation at all. That reaches an association only where it opens a facility to the public — a clubhouse rented for outside events, a pool or golf course selling non-resident memberships. A members-only association website is a much weaker target.

Nothing changed at the IRS. The “About Form 1120-H” page, last updated March 30, 2026, lists “Recent Developments: None at this time.” Three traps survive untouched: the Revenue Ruling 70-604 election is annual and must be made by the members, not the board; it cannot be used to sweep a year-end surplus into reserves, which is what most boards want it for; and filing Form 1120-H is itself an annual election rather than a status.

That last point now collides with the reserve rule. The secondary market will require 15 percent of assessment income in reserves from January 4, 2027, while the tax rules still make it awkward to move a year-end surplus into reserves without tax. The money has to be budgeted into reserves, not swept there afterwards.