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One Community - One Keystone



CTA Reporting Requirements

  • 6 Oct 2024 11:25 AM
    Quote
    Message # 13416116
    Tim Huiting (Administrator)

    From Ken Riley, President - Soda Spring

    How are HOAs handling the CTA reporting requirements: self-reporting, hiring someone (who?), or your Property Management Company?
  • 6 Oct 2024 12:17 PM
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    Reply # 13416126 on 13416116
    Michael Mac - Montezuma

    Our management company, Buffalo Mtn Mgt, Is planning to send out a questionnaire/info gathering email to board members and they will complete/submit the documentation

    =================================
    The Corporate Transparency Act (CTA) requires reporting companies to file a Beneficial Ownership Information Report (BOI Report) with the Financial Crimes Enforcement Network (FinCEN). The BOI Report must include the following information:

    Reporting company

    The company's legal name, trade name, and address, as well as its jurisdiction of formation or registration

    Beneficial owners

    The full legal name, birth date, address, and a unique identifying number for each beneficial owner

    Company applicants

    The legal name, birth date, and address for each company applicant

    Taxpayer identification number

    The company's IRS Taxpayer Identification Number (TIN), or a tax identification number from a foreign jurisdiction

    Identification document image

    An image of the approved document that contains the identifying number for each beneficial owner

    Reporting companies must also update their BOI Report within 30 days of any changes, and file an annual report confirming the accuracy of their information.

    The CTA's reporting requirements went into effect on January 1, 2024, but businesses formed before that date have until January 1, 2025 to comply.
  • 6 Oct 2024 2:00 PM
    Quote
    Reply # 13416162 on 13416116
    Ron Ellis

    Regarding CTA reporting requirements our Management Company wants nothing to do with it.  Altitude Law group says they will do it for $400 per year (whole Board I assume) and $100 per update.  This is the way Tennis Townhouses is going to go.
  • 6 Oct 2024 4:05 PM
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    Reply # 13416190 on 13416116
    Joan Lavell, Seasons at Keystone

    Our management company is handling this.  The major work up front is getting each board member to file for a FinCEN number through FinCen.  Then the HOA is obligated to notify FinCEN within 30 days of any board member changes, and of course there are fines associated with late filing.  I had to make a filing for my business and it was easy once you have the board members' FinCen numbers because there is little else to fill out.  I'm a little amazed at what Altitude is charging.  The trick is staying on top of this. 
  • 18 Oct 2024 6:42 AM
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    Reply # 13420580 on 13416116
    Thaison Do - Key Condo HOA

    There are still pending lawsuits, but none are likely to be settled before the December 31st deadline to file the BOI report.  To file, I saw a lot of comments about sending questionnaires and collecting information.  I personally am opposed to collecting people's private personal info just to have it saved in folder or just lying around somewhere.  I would recommend instead of collecting any private information, regardless of how innocuous it might be, to have identify anyone you consider a "beneficial owner" (most likely the members of the HOA board, unless you have any one owner who owns at least 25% of your units) and have them file for and individual FinCEN ID. 

    https://fincenid.fincen.gov/landing

    It only takes a few minutes, and the only info required is:

    -Full legal name

    -Residential Address

    -Date of Birth

    -Photo or scan of a government issued ID

    The individual does it themselves, so no private info is being sent back and forth or otherwise left somewhere to be seen by someone not authorized to see it.  When you file your BOI, you just provide the 12-digit FinCEN ID of all your "beneficial owners" instead of providing any private info that they haven't already provided to FinCEN themselves.

    Thaison
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