How-To

How to Report Beneficial Ownership Information for HOAs with a Free Preparation Worksheet

For most homeowners associations, the deadline to report beneficial ownership information is January 1, 2025. Use the free preparation worksheet and follow this guide for a step-by-step outline to meet reporting requirements and avoid penalties.

2 months ago   •   7 min read

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How to Report Beneficial Ownership Information for HOAs
Table of contents

Not sure what the Corporate Transparency Act (CTA) is or how it impacts HOAs? First, check out our article, Understanding the Corporate Transparency Act for HOAs, to learn the basics of the CTA.

Once familiar with the CTA, this guide will walk you through filing a Beneficial Ownership Information (BOI) Report for your HOA. We'll also provide a free preparation worksheet to help you organize the necessary information and ensure a smooth filing process.

🏛️
Update #2 on December 5, 2024: A federal judge in Texas has blocked enforcement of the Corporate Transparency Act nationwide. [7]
On December 3, 2024, U.S. District Judge of the Eastern District of Texas issued a preliminary ruling that temporarily blocks the CTA and FinCEN's rule requiring companies to report their BOI. The ruling means:
1. The CTA and the rule requiring BOI reporting is paused.
2. The January 1, 2025, deadline for reporting is paused.
3. Companies do not need to comply with the BOI reporting deadline until the court decides further.

Update #1 on October 24, 2024: CAI's motion for a preliminary injunction was denied. HOA's must report BOI to FinCEN.

Note: The requirement for HOAs to file under the CTA is being contested in court. HOAs may choose to delay filing their Beneficial Ownership Information Report (BOIR) as the outcome of the CAI vs. Department of Treasury case, which could be decided before the end of the year, may impact filing obligations.

October 2024: CAI’s motion for a preliminary injunction was denied
On October 11, 2024, a U.S. District Court in Virginia heard a case to decide whether the CTA applies to Community Associations Institute (CAI) members. However, on October 24, the court denied CAI’s motion for a preliminary injunction, meaning that, for now, HOAs remain subject to the CTA’s reporting requirements.[1][5]

June 2024: Oregon Court Denies Injunction Against CTA
A federal court in Oregon denied a motion for a preliminary injunction, keeping the CTA in effect while the case continues.[2]

March 2024: Alabama Court Declares CTA Unconstitutional for Specific Parties
In March 2024, a federal court in Alabama ruled the CTA unconstitutional, but only for the plaintiffs in the case - National Small Business Association (NSBA) members. Other entities, including most HOAs, are still required to comply as the ruling is being appealed. [3]

How to File a Beneficial Owner Information Report (BOIR)

Filing a BOIR requires specific details about each beneficial owner. Here's what needs to be included:

BOI Report Requirements

To file a BOIR, you'll need to provide specific details about your HOA and its beneficial owners. Here's what you'll need:

  • The HOA information
  • Information for each beneficial owner including:
    • The full legal name
    • Residential address (not a business address)
    • Date of birth
    • Unique identifying number from an acceptable identification document (e.g., driver's license, passport)
    • Image of the identification document (e.g., a clear photo of the driver's license or passport)

Steps to Electronically File a BOIR

  • Gather the Required Information. Use the worksheet provided below.
  • Visit FinCEN's BOI E-filing Website. Then click "File BOIR" or "Get Started" with E-Filing.
FinCEN's Website
  • Click Prepare & Submit BOI to e-file.

Filing Information

  1. Select Type of filing.
    1. Initial report if this is the first BOIR filed for the reporting company.
    2. Correct prior report if the report corrects inaccurate information from a previously filed BOIR.
    3. Update prior report if the report updates a previously filed BOIR, for example, to add one or more new beneficial owners.
    4. Newly exempt entity if after having filed a BOIR, the reporting company is now exempt from BOI reporting requirements.
  2. Date prepared is auto-filled.
BOIR Step 1. Filing Information
BOIR Step 1. Filing Information

Part I. Reporting Company Information

  1. Select Request to receive FinCEN ID if you would like a unique identifier. A FinCEN ID is not a requirement for BOI reporting[4].
  2. Select Foreign pooled investment vehicle if you're an overseas investment fund where multiple investors' money is combined to invest in the various assets. [5].
  3. Enter your official HOA name as the Reporting Company legal name. You can find this in your Articles of Incorporation or by looking it up from the Secretary of State registration. Refer to our detailed guide on How to Verify Your Homeowners Association's Corporate Status: A State-by-State Guide for California, Florida, and Texas.
  4. Enter your HOA's Alternate name, if applicable.
BOIR Steps 3-6. Reporting Company Information
BOIR Steps 3-6. Reporting Company Information

Reporting Company: Form of Identification

  1. Enter your HOA's Tax Identification Type, typically EIN which can be found on your tax filing.
  2. Enter your Tax Identification number.
  3. Unless you select "Foreign" in Step 7, you won't be required to select a country
  4. For Jurisdiction of formation or first registration:
    1. Select Country
    2. State of formation
    3. Tribal jurisdiction of formation
    4. Name of the other Tribe
BOIR Steps 7-10. Form of Identification
BOIR Steps 7-10. Form of Identification

Reporting Company: Current U.S. Address

  1. Enter your HOA's address.
  2. Enter your HOA's City.
  3. Select your HOA's Country
  4. Select your HOA's State.
  5. Enter your HOA's ZIP code.
BOIR Steps 11-15. Current U.S. Address
BOIR Steps 11-15. Current U.S. Address

Part II. Company Applicant Information

  1. Check Existing reporting company if the reporting company was created or registered before January 1, 2024.
  2. (This item is reserved for future use)
Step 16. Existing Reporting Company
Step 16. Existing Reporting Company
❗
Checking step 16 will allow you to skip to Step 35.

Part III. Beneficial Owner Information

For each Beneficial Owner:

  1. Check Parent/Guardian information instead of minor child if Beneficial Owner is a minor child and the parent/guardian information is provided instead
  2. Enter FinCEN ID if you have one.
  3. Check Exempt entity if the beneficial owner holds its ownership interest in the reporting company exclusively through 1 or more exempt entities and the name of that exempt entity or entities are being reported in lieu of the beneficial owner's information.
BOIR Steps 35-37. Beneficial Owner Information
BOIR Steps 35-37. Beneficial Owner Information

For the Beneficial Owner:

  1. Enter the Individual's legal last name or entity's legal name.
  2. Enter the legal First name.
  3. Enter the legal Middle name if applicable.
  4. Enter the legal Suffix if applicable.
  5. Enter the Date of birth.
  6. Enter the residential Address.
  7. Enter the residential City.
  8. Select the residential Country/Jurisdiction.
  9. Select the residential State.
  10. Enter the residential ZIP/Foreign postal code.
Steps 38-47. Legal Name and Residential Address
Steps 38-47. Legal Name and Residential Address

For the Beneficial Owner:

  1. For the Identifying document issuing jurisdiction:
    1. Select a Country
    2. Select a State
    3. Select a Local/Tribal
    4. Enter Other local/Tribal description
  2. Upload the Identifying document image as a .jpg, .png, or .pdf (File must be smaller than 4MB).

Click Add Beneficial Owner for the next entry.

BOIR Steps 48-51. Form of Identification and Issuing Jurisdiction
BOIR Steps 48-51. Form of Identification and Issuing Jurisdiction
  • Submit the BOIR
    • Enter the authorized submitter's Email, First Name, Last Name
    • Check I agree to certify that you are authorized to file this BOIR and that the information contained in the BOIR is true, correct, and complete.
    • Check I am human captcha.
  • Download a transcript of the BOI Report.
Submit BOIR
Submit BOIR

Conclusion

Filing a BOI Report for your HOA may seem like a complex task, but with the right preparation, it can be handled efficiently. Gathering the required information, using our preparation worksheet, and following the steps outlined in this guide can ensure that your HOA complies with the Corporate Transparency Act (CTA).

Ready to get started? Download the free worksheet and start preparing today to avoid unnecessary penalties and ensure a smooth filing process.

Footnotes & References

  1. Community Associations Institute. October 11, 2024 Corporate Transparency Act Update: Key Hearing Held in Lawsuit.
  2. Wolters Kluwer. September 30, 2024. Federal District Court in Oregon denies motion for preliminary injunction in Corporate Transparency Act lawsuit.
  3. Gibson Dunn. March 18, 2024. The Corporate Transparency Act Declared Unconstitutional: What It Means for You.
  4. Wolters Kluwer. June 4, 2024.Do I need a FinCEN ID?.
  5. FDIC. Section 7 - Compliance - Pooled Investment Vehicles.
  6. Community Associations Institute. October 24, 2024 Lawsuit FAQ Fail.

Disclaimer: The information provided in this article is intended for general informational purposes only. It does not constitute legal, financial, or professional advice, nor is it a substitute for consulting with qualified professionals. While we strive to provide accurate and up-to-date information, we make no guarantees regarding the applicability or accuracy of any information provided. Users are encouraged to consult with a qualified attorney, financial advisor, or legal professional for advice tailored to their specific situation. reTHINK HOA is not responsible for any actions taken based on the information provided in this article.

BOI Report Preparation Worksheet

Get organized for your BOI report filing with our BOI Report Preparation Worksheet. This worksheet will help ensure you have all the necessary information ready before you begin the filing process.

Sign in or Subscribe to download the worksheet below! If you have any questions or need further assistance, please comment, and we'll be happy to help.

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