As of early 2025, the Corporate Transparency Act (CTA) remains a significant compliance factor for incorporated community associations nationwide, including those in Washington State. While the initial BOI (Beneficial Ownership Information) reporting deadline has passed, continuous compliance and awareness of potential updates are vital. The CTA’s implementation and enforcement are still subject to refinement, and legal challenges continue to influence its interpretation.
Current Reporting Obligations:
Incorporated community association boards are mandated to file a Beneficial Owner Information (BOI) report with the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN). This report necessitates the disclosure of identifying information pertaining to the association’s beneficial owners, specifically those individuals who exercise substantial control, such as current board members.
Community associations are obligated to update their BOI report within 30 days of any changes to the board of directors, whether due to appointment or resignation.
Key Considerations for Washington State Community Associations in 2025:
Ongoing Legal Scrutiny and Potential Amendments: The CTA is still subject to legal challenges and potential congressional amendments. Associations must remain vigilant regarding updates to the law and its interpretation.
Consult Legal Counsel: Given the complexity and evolving nature of the CTA, it is strongly advised that incorporated community associations in Washington State consistently consult with legal counsel specializing in community association law. This is essential to ensure compliance with federal mandates and to address any potential interplay with evolving Washington state regulations.
FinCEN Updates and Compliance: Associations should regularly review the latest FinCEN guidelines and updates issued by the Treasury Department. The official FinCEN website remains the authoritative source for this information.
Financial and Tax Implications: Consult with your association’s accountant to address any financial or tax-related implications stemming from the CTA. This includes understanding potential changes in reporting requirements and their impact on the association’s financial operations.
State Law Alignment: While the CTA is a federal statute, it is crucial to stay informed about any related or potentially conflicting requirements under Washington state law. Legal counsel can assist in navigating these complexities and ensuring alignment with both federal and state mandates.
Record Keeping: Maintain meticulous records of all BOI reports and related documentation. This includes keeping track of FinCEN IDs, board member changes, and any updates to the association’s information.
By staying informed and seeking professional guidance, Washington State community associations can effectively navigate the ongoing requirements of the CTA and maintain compliance in 2025 and beyond.
