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Law

The Corporate Transparency Act (CTA) and Homeowner Associations

Homeowner Associations need to be held to the Corporate Transparency Act to protect homeowners from abusive, illegal, and criminal behavior. This page contains information for understanding the CTA and what it does, as well as resources for advocating to hold HOAs to comply with it.

In fairness, I have also added CAI's response to the CTA

and their argument for exempting HOAs from it.

 

​

​As of 3/25/25, all articles indicate that the CTA/BOI requirements will only apply to

foreign or international companies. At this time, it seems the matter has been concluded with HOAs eluding this mechanism of accountability -- for now.

  • As of 3/25/25: THIS ARTICLE from The National Law Review.

  • As of 3/4/25: THIS ARTICLE from The National Law Review;
    "Now, with FinCEN’s March 2, 2025 announcement, and presuming that the Treasury Department does not change course again, domestic entities will not need to file BOIRs."

  • As of 3/3/25: THIS ARTICLE from The Citizen: "Georgia Secretary of State Brad Raffensperger, along with several of his colleagues from across the country, sent President Donald J. Trump a formal request urging the immediate repeal of the Corporate Transparency Act (CTA)."

  • As of 3/3/25: THIS ARTICLE from Entrepreneur

  • As of 2/28/28: THIS ARTICLE from ROI-NJ

  • As of 2/27/25: THIS ARTICLE from RePlay Magazine, "AAMA Calls to Repeal Corporate Transparency Act"

  • As of 2/27/25: THIS ARTICLE from CBIZ; "BOI Reporting Requirements are OFF, Again" 

For older, archived articles, please scroll to the bottom of the page

Why Should HOAs Be Held to The CTA?

Deborah Goonan, of Independent American Communities, wrote an excellent blog article on Feb. 11, 2025 which is a concise, intelligent, reasoned, and highly supported argument for why HOAs NEED to be held to the CTA. CAI and others are trying to argue that HOAs are "low risk entities" for crime and fraud (a claim that makes the jaw of anyone in the HOA know hit the ground). Deborah is a highly knowledgeable advocate for homeowner rights who has been active for a decade. I also recommend her podcast interview with USCFAR found HERE for more on her, her work, and for a lively and informative discussion.

What Is The Corporate Transparency Act?

Click Here to access the original Act.

Click Here to access an article by HOA Management that explains the Act and its relationship with HOAs.

Click Here to read an article by HOA Works, which states, "the CTA seeks to make it more difficult for criminals to hide behind anonymous shell companies."

Click Here to view my open letter to the Honorable Michael S. Nachmanoff, Judge for the CAI lawsuit (see below).

Man Signing
In court
Researching and Writing

Resources to Advocate to Hold HOAs to the CTA

As always, contact your local legislators and ask them to join you in demanding that the CTA apply to HOAs and that they be required to comply.

Sign This Petition to require that HOAs be included in CTA compliance.

Send e-mails SEPARATELY to the judge and defense counsel in the CAI lawsuit (see below for more info on the suit):

  1. vaed_clerk@vaed.uscourts.gov     ATTN: Honorable Michael S. Nachmanoff Case 1:24-cv-01597

  2. (Attorney) peter.baumhart@usdoj.gov

      Regarding Case 1:24-cv-01597-MSN-          LRV

The Community Associations Institute (CAI) Lawsuit to Exempt HOAs from The CTA

Click Here to view the PacerMonitor record of the lawsuit.

Click Here to View CAI's statement on the suit and its reasons for it.

Click Here to view a video statement from CAI on the filing of suit.

Click Here to view the CaseText version of Judge Nachmanoff's denial of CAI's motion for a preliminary injunction.

In court

Articles Archive

  • As of 2/24/25: THIS ARTICLE from The National Law Review

  • As of 2/21/25: THIS ARTICLE from JDSupra

  • As of 2/17/25: THIS ARTICLE from ABA Banking Journal

  • As of 2/06/25: THIS ARTICLE from LandLine

  • As of 2/05/25: THIS ARTICLE from The National Law Review

  • As of 1/31/25: THIS ARTICLE from Business Law Group

  • As of 1/30/25: THIS ARTICLE from Frost, Brown & Todd

  • As of 1/28/25: THIS ARTICLE from Crowell & Moring LLP

  • As of 01/20/25:  THIS ARTICLE, "A response was filed ..."                                                     Also see THIS ARTICLE on concerns of negative impacts of the CTA.

  • As of 12/27/24: The Fifth Circuit Court of Appeals lifted the injunction. More information is in THIS ARTICLE.

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