What is CTA?

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).

What is a BOI?

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.

Why does my HOA have to report?

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.

What happens if we don’t report?

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.

Who has access to this 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 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.

Do we have to use a Third-Party to submit our BOI Filing?

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.

What does your service include?

  1. Assistance with data gathering 
  2. Data Management
  3. Customized Reporting
  4. Ongoing Compliance Monitoring

Why does CTA Review work only with HOA’s?

The founders of CTA Review have over 20 years of experience in the HOA industry. We understand the nuances of serving on a Board 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.

What is your pricing structure?

The first filing for your community comes at a flat rate of $375. For annual updates, or mid-year changes to the Board of Directors the cost is $275.

If there are no changes required for the year, there won’t be any additional fees. We’ll keep an eye on your filing and alert you to any issues, such as expired IDs, as part of our service.

Invoices are due net 30.

Who is 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.