Corporate Transparency Act – Illinois Community Associations MUST File by December 31, 2024

May 15, 2024 | Articles

As most readers are aware, the Corporate Transparency Act (“CTA”) and compliance requirements for Illinois community associations have been a hot topic this year. Managers and board members have been confused by court rulings, legislative maneuvering by lobbyists to exempt condos and HOAs, and conflicting information.

However, just last month, the Financial Crimes Enforcement Network (FinCEN) sent out updated guidance addressing the CTA and its impact on community associations and has put to rest any questions. Subject to a limited number of exceptions, the board members (and managers) of condominium and homeowner associations must comply with the reporting requirements before the December 31, 2024 deadline. This will require some administrative work by the associations, including collecting names, addresses, and driver’s license information for each board member and then uploading that information onto the FinCEN website.

As of now, BRK is advising clients to wait until later in the summer of 2024 and even into autumn 2024 to ensure that each association needs to file only once (each time a board changes, a new filing must be completed). Given the fact that most annual meetings/elections occur in summer and fall, we aim to have our clients file one time only in 2024 if possible.

A comprehensive list of FAQs issued by FinCEN is available at this link here. You will note certain questions specifically address the issue of homeowners associations and their reporting duties.

Stay tuned for further updates and information this summer on how BRK can assist your community with the filing requirements to ensure compliance.

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