BOI Reporting Platform For HOA Community Managers

The vast majority of homeowners and condo associations must file beneficial ownership information (BOI) reports to avoid FinCEN penalties. Any HOA or condo association using a formal entity structure (e.g., corporation or LLC) registered with any state must begin BOI reporting in 2024, barring specific exemptions. Failure to file can result in significant FinCEN fines.

Only two rare exemptions apply to HOAs: tax-exempt non-profits under section 501(c)(4), and unincorporated condominium associations in certain jurisdictions like New York. Generally, FinCEN considers HOAs and condo associations as reporting companies subject to filing requirements.

Existing communities established before 2024 must file initial reports by January 1st, 2025.

Communities formed in 2024 have a 90-day window from their creation date to file.
 
Starting in 2025, new communities will have only 30 days to submit their initial report. It’s crucial to note that HOAs and condo associations often require frequent report updates due to annual elections and board member changes. These events necessitate filing an updated report within 30 days to avoid penalties.

Reports must be filed for every entity within a community’s operational structure, unless exempt. These reports should include the entity’s legal name, formation state, any DBA names, tax ID number, business address, and information about individuals with substantial control.

The report must include all individuals with substantial control over community management, typically encompassing all voting board members. Substantial control broadly refers to the ability to influence important entity decisions, such as community matters, vendor hiring, or asset management.
 
While FinCEN usually requires reporting individuals owning 25% or more of an entity, this rarely applies to HOAs or condo associations unless someone owns over 25% of the community’s homes or units.

Almost invariably, yes. Board members vote on crucial
community matters, hire vendors, manage assets and finances, sign essential
documents, and conduct critical business through their entities.

FinCEN reporting mandates that each board member with substantial control provide their full name, birth date, primary residential address, ID number, and an image of their identification (e.g., driver’s license or passport) on every BOI report. Our platform simplifies the secure collection of these details from board members.

Yes. Communities must submit updated reports to FinCEN within 30 days of any changes to previously reported information.
 
Common triggers for updated reports include board member additions or removals, changes to a board member’s identification number or address, and updates to community information like a new office address or DBA name. These updates maintain the accuracy and compliance of the community’s FinCEN database records.
 
Our platform can send regular reminders to keep board members informed of these triggers, helping avoid FinCEN’s $500 daily fines. Community managers can leverage this feature to offer ongoing CTA compliance services to their communities.

FinCEN’s penalties for late or non-filing include $500 daily fines, $10,000 penalties, and potential imprisonment for up to two years. Communities must take these new filing requirements seriously. Fortunately, our platform enables communities to file quickly and securely through their community manager.

Two rare exemptions under the Corporate Transparency Act (CTA) may apply to HOAs:
1. HOAs that are tax-exempt non-profits under section 501(c)(4) (not applicable to most communities).
2. Unincorporated condominium associations in certain jurisdictions like New York.
 
Generally, FinCEN considers most HOAs and condominium associations as reporting companies required to file reports.

Our platform streamlines report filing and ongoing compliance management. Community managers can send secure BOI collection links to board members, with automatic reminders until completion. Once all information is gathered, the community manager can e-file the BOI report to FinCEN with a single click. The system then returns the confirmation transcript and securely stores the record for compliance purposes.
 
Future updates are simplified by loading prior report data for quick modifications and refiling. Regular compliance reminders keep board members aware of update requirements, allowing one-click update requests for mid-year or post-election changes. Community managers can even bulk-import community data using CSV files for added efficiency.