CTA NATIONAL UPDATE: Corporate Transparency Act Suspended for Domestic Reporting Companies

This article was originally published on March 3, 2025 by Community Association Institute for Community Association Institute Advocacy Blog.

On March 2, the U.S. Treasury Department issued a statement regarding enforcement of the Corporate Transparency Act.   

The official notice says, “not only will it not enforce any penalties or fines associated with the beneficial ownership information reporting rule under the existing regulatory guidelines, but it will further not enforce any penalties or fines against U.S. citizens or domestic reporting companies or their beneficial owners after the forthcoming rule changes take effect either.”   

Further, the department said it will be issuing a proposed rulemaking to narrow the scope of the act to foreign reporting companies only.  

This recent action is interpreted to mean the Corporate Transparency Act and its reporting requirements are no longer in effect for U.S. citizens or domestic reporting companies, including all applicable community associations.   

We thank the many CAI advocates who contacted their members of Congress to express their opposition to the act’s reporting requirements for community associations. Your voices were heard!  

CAI’S FEDERAL LAWSUIT STATUS

On October 24, 2024, CAI’s preliminary injunction request was DENIED by the federal judge in this case. While this decision was not the outcome CAI had hoped for, it does not mark the end of CAI’s efforts. CAI appealed the court’s denial of the preliminary injunction request on November 4, 2024, and on November 12, 2024, filed its opening brief of the appeal in the Fourth Circuit urging a pause on reporting requirements for community associations while this lawsuit is adjudicated. The Government filed it response to CAI's appeal on February 7, 2025. CAI filed its reply on February 28, 2025.

CAI’s other lobbying and advocacy efforts continue on Capitol Hill seeking both a one-year delay of implementation of the CTA’s reporting requirements and an exemption for community associations. The lawsuit itself is continuing to go through the legal process even as the preliminary injunction decision is being appealed.