Corporate Transparency Act Déjà Vu All Over Again – CTA Reinstated Once More: What Do Illinois Community Associations Need To Know?

Stop us if you’ve heard this before: the Corporate Transparency Act (“CTA”) and its mandatory reporting requirements are back in effect, this time with a new reporting deadline of March 21, 2025.

Recently, the U.S. District Court for the Eastern District of Texas reinstated the CTA’s reporting obligations, reversing a previous nationwide injunction that had temporarily paused these requirements. This decision means that all entities subject to the CTA, including most condominium and community associations and co-ops, are once again legally obligated to file beneficial ownership information with the Financial Crimes Enforcement Network of the U.S. Treasury Department (“FinCEN”). In response to this latest ruling restoring the CTA’s mandatory reporting requirements, FinCEN has once again extended the initial filing deadline. The new reporting deadline for the vast majority of companies is March 21, 2025. Click here for FinCEN’s February 18^th notice of this new, extended deadline. 

This ruling (and resulting updated initial reporting deadline) is the latest in a series of challenges to the CTA’s reporting requirements and is not a final ruling on the constitutionality of the CTA. As we have previously noted, clarity regarding the fate of the CTA and its reporting requirements is expected in the coming weeks and months as the issue evolves. For now, community associations that have not yet completed their initial CTA reporting with FinCEN need to do so by the new March 21^st deadline. For community associations that have already completed their initial CTA filing, no further action is needed in response to this latest ruling. 

LP is committed to keeping our community association clients informed of, and prepared to proactively and successfully navigate, any changes in the law. For questions regarding the CTA, including reporting requirements, or other issues facing your condominium or community association or co-op, please contact Howard Dakoff, Laura Marinelli, Adam Kahn, or Molly Mackey of LP’s Community Association Group.