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What the FinCEN Changes to the Corporate Transparency Act Mean for NJ Condominium and Homeowners’ Associations
By September 3, 2026 Posted in Community Association Law Share
Previously, New Jersey condominium association Boards and homeowners’ associations Boards have received relief from the reporting requirements imposed under the federal Corporate Transparency Act (“CTA”). The Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) has removed the requirement for U.S. companies and people to report beneficial ownership information under the CTA. As a result, community housing associations, including condominium associations and homeowners’ association, are no longer required to submit beneficial ownership information reports that detail board members and/or other individuals who may have “substantial control” over the association.
FinCEN has also announced that it will delete previously reported beneficial ownership information submitted by entities/people who are now exempt from the reporting requirements from its beneficial ownership information database. As such, associations that retained CTA-administrators or services solely for this reporting no longer need to expend funds on those services.
The CTA created specific concerns for condominium associations and homeowners’ associations because board members could have been classified as beneficial owners due to their decision-making authority. As a result, these associations had to consider collecting and reporting board members’ personal information and updating those reports when board members changed. Under the current FinCEN regulations, condominium associations and homeowners’ associations should no longer need to:
- File initial or updated beneficial ownership information reports;
- Report changes in Board members;
- Collect identifying documents from Board members strictly for CTA reporting purposes;
- Maintain CTA-specific procedures for new Board members; or
- Retain and pay a third-party CTA administrator solely for beneficial ownership information reporting.
Associations that previously had CTA compliance procedures should review and discontinue unnecessary beneficial ownership information reporting. Associations should review whether there remains any need to collect or retain Board members’ personal identifying information that was collected solely for CTA reporting purposes, as the CTA no longer requires collection or reporting of that information. Associations that previously filed beneficial ownership information reports do not need to submit updates based on subsequent changes to their Boards.
This change is to federal CTA beneficial ownership information reporting, and it does not affect an association’s obligations under their governing documents or NJ law. The FinCEN changes only remove the additional federal beneficial ownership information reporting burden that has been imposed on such Associations and their Board members. Therefore, Associations that have compliance requirements as part of their governing documents or have other reasons to comply with CTA beneficial ownership information reporting, may still have to continue with their reporting procedures.
The information in this Client Alert is provided solely for information purposes. It should not be construed as legal advice on any specific matter and is not intended to create an attorney-client relationship. The information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular circumstances. Each legal matter is unique, and prior results do not guarantee a similar outcome.