Welcome to CTA Review

Your HOA’s trusted partner for CTA compliance and monitoring.

  • BOI reporting service exclusively for HOA’s
  • Unlimited updates for one low price
  • User friendly platform
  • Trusted industry partner with over 20 years of HOA experience
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Important Notice:

On December 3rd, the U.S. District Court for the Eastern District of Texas issued a preliminary nationwide injunction against the Corporate Transparency Act (CTA), temporarily halting enforcement of the beneficial ownership reporting requirements, including the January 1, 2025 deadline. This injunction is widely believed to apply nationwide, including community associations and other owners’ associations. On December 5th, the government filed a notice of appeal to the Fifth Circuit Court. This could lead to a reversal or limit the ruling to the plaintiffs involved. The timeline and outcome of the appeal remain uncertain.

Please note,  a preliminary injunction is not a final decision. It is expected that the government will continue to litigate.  They may seek an immediate stay from the Fifth Circuit Court of Appeals, which, if granted, could reinstate the January 1, 2025 deadline. While a stay might create time pressures for companies waiting to file, we hope any decision won’t come at the last minute. If the Fifth Circuit denies the stay, the government could appeal to the Supreme Court.

FinCEN may also issue guidance on this case.  We will keep you updated on any new developments.

CTA Review Client Options:

  1. Continue with the process: Proceed with collecting information and filing with FinCEN. (No action necessary)
  2. Hold filing: Continue collecting information and preparing the BOI report, but hold off on filing until the injunction is lifted.
  3. Pause the process: Stop all collection efforts and wait to see how the situation develops.

There are many differing legal opinions and numerous unknown factors at play. To maintain the high level of service our clients deserve, we are invoicing for all files. This ensures we can continue to collect information and be prepared to file if needed.  Some clients prefer to proceed with filing now rather than wait. If the injunction is overturned in the coming weeks, there may be a rush to comply. However, it’s also possible that the injunction remains in place.

For specific guidance, we recommend consulting your HOA’s legal counsel.

If we do not receive a Hold or Pause request through our webform here we will proceed with Option 1 and continue the process as planned.

About The Corporate Transparency Act

The basics of the new federal requirement, FinCEN, and the effects on your HOA.

What is the CTA?

In 2021, Congress passed the Corporate Transparency Act, a new law designed to bolster law enforcement efforts in preventing, identifying, and addressing financial crimes. Under the CTA, the majority of businesses are mandated to submit a report to the Financial Crimes Enforcement Network (FinCEN).

Does My HOA need to file?

The short answer is yes. Unless your community has 20 or more employees and $5 million in gross receipts or sales, as reflected in the previous year’s federal tax return, your community is not exempt.  Each director on the HOA board will need to file a beneficial ownership informational form with FinCEN.  If you have specific questions we suggest contacting your legal counsel or CPA for a professional opinion.

How Often?

Communities established before January 1, 2024, have until January 1, 2025, to submit their initial report. (Deadline is on hold as of 12/4/2024)

While there’s no yearly reporting obligation, BOI reports should be regularly reviewed and amended when necessary. Updates are required within 30 calendar days of changes such as turnover in board members, primary residence alterations, or expired IDs.

The Corporate Transparency Act – The Basics for HOAs by CTAReview

Get your HOA FinCEN compliant today.

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Maintain Compliance

Annual compliance plans available for existing customers

Initial Filing & Compliance

$295

  • Set up of Property Profile with CTA Review
  • Initial BOI Report and Certificate of Compliance
  • Unlimited BOI report updates for one year from the date of initial filing
  • Updated BOI Certificates provided as needed
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Compliance matters

HOA’s must comply by January 1, 2025

Under the new Corporate Transparency Act (CTA), every HOA Board Member, nationwide, must submit a BOI report with contact information to FinCEN.

Personal Information

Directors serving on an HOA Board must provide some personal information to maintain compliance with this new law.

This information includes your address, DOB, and a copy of your driver’s license or passport.

Who has access to my personal information?

The information shared with FinCEN is kept private. The CTA makes sure of this by stating that Beneficial Ownership Information (BOI) is confidential and cannot be shared unless allowed by the CTA and the Access Rule. FinCEN is allowed to share BOI with certain groups under specific conditions:
1. U.S. Federal agencies involved in national security, intelligence, or law enforcement.
2. U.S. State, local, and Tribal law enforcement agencies.
3. Foreign law enforcement agencies, judges, prosecutors, central authorities, and competent authorities (if requested).
4. Financial institutions need BOI to follow customer due diligence (CDD) rules under the law.
5. Federal regulators and other agencies supervising financial institutions for CDD compliance under the law.
6. Officers and employees of the Treasury Department.

Non Compliance

Not following the rules of the CTA is risky, especially for the Board of Directors. If they don’t report the required information, or give false details, they face the risk of the following:

Civil Penalties: Top officials could be fined up to $591 every day they don’t follow the rules or give false info. This fine adds up fast and could end up being a lot of money, but it won’t go over $10,000.

Criminal Penalties:  Besides monetary penalities, there are also criminal consequences. If Board Members willfully provide false information to FinCEN or don’t update as needed, they could go to jail for up to two years.

Common Questions

The Corporate Transparency Act (CTA) is a federal law aimed at stopping illegal activities like money laundering in the US financial system. It requires certain companies, including homeowners associations (HOAs), to give details about who owns or applies to own them to the Department of Treasury’s Financial Crimes Enforcement Network (FinCEN).

BOI stands for Beneficial Ownership Information. It refers to details about individuals who ultimately own or control a legal entity, such as a company or organization. This information helps authorities understand who is behind a business and is crucial for combating financial crimes like money laundering and terrorism financing.

Unfortunately, most HOAs can’t skip the reporting. Even though they often run as nonprofits, they usually don’t qualify as charitable organizations under tax laws. Unless they’re registered as a specific kind of nonprofit with the IRS (Section 501(c)(3)), it’s best for them to follow the rules of the Corporate Transparency Act (CTA) and report their ownership details.

Not following the rules of the CTA is risky, especially for the Board of Directors. If they don’t report the required information, or give false details, they face the risk of the following:

Civil Penalties: A person who willfully violates the BOI reporting requirements may be subject to a penalty of $591 each day that the violation continues.

Criminal Penalties:  A person who willfully violates the BOI reporting requirements may also be subject to criminal penalties of up to two years imprisonment and a fine of up to $10,000.

The information shared with FinCEN is kept private. The CTA makes sure of this by stating that Beneficial Ownership Information (BOI) is confidential and cannot be shared unless allowed by the CTA and the Access Rule. FinCEN is allowed to share BOI with certain groups under specific conditions:

1. U.S. Federal agencies involved in national security, intelligence, or law enforcement.

2. U.S. State, local, and Tribal law enforcement agencies.

3. Foreign law enforcement agencies, judges, prosecutors, central authorities, and competent authorities (if requested).

4. Financial institutions needing BOI to follow customer due diligence (CDD) rules under the law.

5. Federal regulators and other agencies supervising financial institutions for CDD compliance under the law.

6. Officers and employees of the Treasury Department.

No, you are not required to use a third party to submit your Beneficial Ownership Information (BOI) filing. As a company or organization subject to BOI reporting requirements, you have the option to submit the necessary information directly to the appropriate authorities yourself. However, some entities may choose to utilize third-party services like CTA Review for assistance with the BOI reporting process, especially if they prefer to outsource this task for efficiency or expertise reasons. Ultimately, the decision to use a third party is up to your organization’s preferences and needs.

  • Assistance with data gathering 
  • Data Management
  • Customized Reporting
  • Ongoing Compliance Monitoring

The founders of CTA Review have over 20 years of experience in the HOA industry. We understand the nuances of working with HOA Boards and the importance of protecting members’ privacy while following the law. We know the risks of managers filing incorrectly and the relief of using a third party to handle it.

By working with us, managers can focus on their tasks without worrying about handling sensitive information. We’re here to help bridge any information gaps during transitions and provide ongoing support.

The initial filing for your community is $295 and includes one year of unlimited updates.

Our monitoring process will send out quarterly reminders to update CTA Review with any BOI changes needed and we’ll monitor the information for any issues.

Invoices are due net 30.

About CTA Review

CTA Review is a specialized third-party service dedicated to facilitating the Beneficial Ownership Information (BOI) reporting procedure. As a sister organization to FHA Review, which has been operating since 2010 and specializes in reviewing and submitting Condo Associations for FHA and VA Approval, CTA Review recognized a natural alignment between its expertise and the BOI reporting process.

Founded on principles of confidentiality and organization, CTA Review ensures the secure handling of private information. Their tailored databases are designed to monitor sensitive data and expiration dates, guaranteeing that your community remains up-to-date with its BOI filing requirements.

Security is our priority

Learn about the safeguards CTA Review uses to protect your personal information.

Learn about Security