It has almost become a full-time job to monitor what the courts are doing with FinCEN’s new Beneficial Ownership Interest (BOI) reporting requirement. If you have been following my blog series on this topic, you’d know that the courts have been playing ping-pong on whether reporting is required or not since December of last year. It’s evolving so fast, if you read my blog post from two weeks ago you’d know that a court order gave Associations until March 21 to file. However, now the U.S. Treasury Department has spoken and officially stated that it will not enforce the requirement on domestic companies, which would include all of our Washington and Oregon clients.
The U.S. Treasury Department has further said that it intends to push for a change to the legislation so that this reporting requirement will only apply to foreign reporting companies. While this may still evolve further, this does appear to be a win for Associations and will hopefully mean an end to the frequent policy changes and the concern that many Boards and community managers felt about another reporting requirement.
In short, Associations do not need to file their BOI report at this time.
For additional information, on how this requirement has progressed and what it intended to do, please read our prior blog articles on the topic, here, here, and here.
