Oregon HOAs have nothing to file with FinCEN, and never will
Oregon HOAs have nothing to file with FinCEN, and never will
2026-09-15 · Oregon · Compliance
If a vendor is still selling your Oregon homeowners association a beneficial-ownership filing service, it is selling a filing obligation that does not exist. The rule has been settled since March 2025 and was made final on August 14, 2026, and the proof is in the text of the regulation itself.1
What the regulation now says
31 CFR 1010.380(c)(1), as in force:
“(c) Reporting company —(1) Definition of reporting company. For purposes of this section, the term 'reporting company' means: (i) [Reserved] (ii) Any entity that is: (A) A corporation, limited liability company, or other entity; (B) Formed under the law of a foreign country; and (C) Registered to do business in any State or tribal jurisdiction by the filing of a document with a secretary of state or any similar office under the law of that State or Indian tribe.”2
Paragraph (c)(1)(i) — the entire domestic reporting company category — has been deleted and marked [Reserved].
Why that ends the question for an Oregon association
An Oregon homeowners association or condominium association is almost always incorporated as an Oregon nonprofit corporation under ORS chapter 65. It is formed under the law of Oregon, not of a foreign country. It therefore does not meet the definition of a reporting company, and the exemption analysis is never reached.
There is nothing to file, nothing to update, and nothing to correct — including for associations that filed in 2024 or early 2025.
FinCEN's own guidance page states it without qualification: “U.S. companies are exempt from the Beneficial Ownership Information (BOI) reporting requirements.”3
The instrument, for the record
The final rule is “Beneficial Ownership Information Reporting Requirement Revision,” 91 FR 52508, published and effective August 14, 2026, RIN 1506-AB67, amending 31 CFR part 1010. Its 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 this needs saying at all
Because the Corporate Transparency Act generated more confusion in the community-association sector than any federal measure in years, and the confusion had a commercial dimension.
In 2024, associations across the country were told — correctly at the time — that they were reporting companies, that every board member was likely a beneficial owner, and that filings were due. A market of filing-service vendors grew up around that, pricing per-association or per-beneficial-owner. Then the obligation was narrowed out of existence for domestic entities by the March 26, 2025 interim final rule, and that narrowing has now been finalised.
Residual deadlines in the rule apply only to foreign-formed entities: those registered before March 26, 2025 had until April 25, 2025, and those registering on or after that date have 30 calendar days. No Oregon association is in that population.
What remains for a board
Check the management agreement and the vendor invoices. If anyone is still billing for beneficial-ownership filing, compliance monitoring, or annual BOI updates, that line item is for work that cannot be required.
Then leave the 2024 filing alone. There is no obligation to correct or update a report that was filed when the rule required it, because there is no ongoing reporting obligation to attach an update to. FinCEN has not asked domestic entities to do anything with historical filings.
What did not change
Every Oregon corporate obligation an association actually has. It is still an ORS chapter 65 nonprofit corporation, and still files with the Oregon Secretary of State's Corporation Division to stay in good standing. Failing to do that has consequences the federal rule change does nothing about.
One 2025 change is worth knowing: House Bill 3588, chapter 158, Oregon Laws 2025, effective May 27, 2025, permits the Secretary of State to accept a commercial mail receiving agency as a business entity's principal office, records office address or principal address where the physical street address would otherwise be the same as an individual's residence.4
That is a real privacy improvement for Oregon associations. Self-managed communities and volunteer boards have had to publish a director's home address as the corporation's address of record. A private mailbox can now stand in.
Separately, a condominium association's annual report to the Oregon Real Estate Agency is a genuine filing with a genuine sanction — a $25 report whose delinquency can, under ORS 100.265(3)(b), stop the association prosecuting or defending a lawsuit. That is the Oregon filing that actually binds a board, not a federal one that no longer applies. Our Oregon director qualifications page covers the corporate side of association governance.
What to watch next
Nothing, on this specific question. The rule is final, the domestic category is deleted, and reinstating it would require new rulemaking with notice and comment. The value in knowing that is not in what a board must do — it is in what a board can stop paying for.
Related Oregon HOA Topics
- Beneficial Ownership Information Reporting Requirement Revision, 91 FR 52508, FinCEN, August 14, 2026 ↩
- 31 CFR 1010.380, Reports of beneficial ownership information — current text, eCFR ↩
- Beneficial Ownership Information, Financial Crimes Enforcement Network ↩
- HB 3588, 2025 Regular Session — business registration addresses, chapter 158, Oregon Laws 2025 ↩
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