CTA SAGA CONTINUES:
NATIONAL STAY ON FILINGS REPEALED BY COURT & NEW REPORTING DEADLINE ESTABLISHED
The United States District Court for the Eastern District of Texas lifted the nationwide stay that had frozen CTA filings across the country this past Tuesday. FinCEN announced on Wednesday that the new filing deadline for most reporting companies is now March 21, 2025.
Additionally, FinCEN noted that the agency will be looking at options to limit reporting requirements for some entities in order to prioritize reporting for those entities which pose the most significant national security risks.
While the constitutional challenges made in federal courts across the country continue, there are also a number of bills in Congress that we are monitoring. One bill in particular already received a unanimous vote in the House of Representatives and aims to delay the CTA filing deadline to January 1, 2026. That bill is currently in the Senate and could be voted on in the coming weeks.
What this means for your Association:
If your Association is formed as a trust or unincorporated entity the CTA likely does not apply and filing the required report may not be necessary. If your Board prefers not to file a report, you may obtain a specific opinion as to your Association. Contact your MEEB Attorney or law@meeb.com to discuss what is right for your Association.
Although some companies have turned filings into a business, we hate the idea that associations have to incur unnecessary expenses to file simple and basic information about the association and board members. If your Association wants to file now, all associations can use MEEB’s free portal to file directly with FinCen. MEEB’s secure portal is directly accessible from our website at www.meeb.com. Filing is easy, and all of the information Board Members need to file is contained on their licenses.
Any MEEB attorney can also assist with CTA questions and file the CTA report for any Association. Contact your MEEB attorney or law@meeb.com if you would like assistance.
The CTA filing requirements have certainly been a rollercoaster over the last few months. We don’t yet know if the pending Senate bill will be passed but we are optimistic of its chances. To that end, please help CAI lobby for the bill’s passage and reach out to your Senators to support H.R. 736 and S. 505 via this link and share this important request with your neighbors.
MEEB has been closely tracking and reporting on this issue and has continued to advocate on behalf of condominium associations that the CTA’s reporting requirements are burdensome, constitute government overreach, and should not apply to homeowner associations.
Stay tuned for further updates. If you have any questions regarding the CTA, please contact your MEEB attorney or law@meeb.com.