Treasury Department Announces Suspension of the Corporate Transparency Act, Exemption for U.S. Citizens and Domestic Reporting Companies: What Do Community Associations Need To Know?

The Corporate Transparency Act (“CTA”) is on hold again, but this time it might be permanent for U.S. citizens and domestic reporting companies.  A recent Treasury Department announcement has (once again) suspended enforcement of the CTA and most importantly, signals the end of the CTA and its mandatory reporting requirements for condominium and community associations and co-ops. 

On March 2, 2025, the Treasury Department announced that it will (i) “not enforce any penalties or fines against U.S. citizens or domestic reporting companies or their beneficial owners”; and (ii) issue a “proposed rulemaking that will narrow the scope of the rule to foreign reporting companies only.” The Treasury Department’s press release is available here.

This press release is the latest in a long line of back-and-forth developments concerning the fate of the CTA. It comes on the heels of a February 27, 2025 announcement (available here) that the Financial Crimes Enforcement Network of the U.S. Treasury Department (FinCEN) would not be issuing fines or penalties in connection with the new March 21, 2025 reporting deadline. This means that there is currently no penalty for missing the current CTA reporting deadline such that the CTA is effectively suspended yet again. 

The proposed rule narrowing the scope of the CTA to foreign reporting companies only has not yet been proposed or adopted but is expected to be released later this month. As such, the CTA is currently on hold once more, but with an expectation that U.S. citizens and domestic reporting companies—including condominium and community associations and co-ops—will be exempted from the CTA in the near future.

It is possible that the announced rule change will not go into effect or that there will be further updates regarding the fate of the CTA as it relates to condominium and community associations and co-ops.  For now, the CTA’s reporting requirements are paused and in light of the Treasury Department’s press release, it is recommended that condominium and community associations and co-ops refrain from voluntarily proceeding with CTA reporting. 

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.