Legislative Updates

Keep up on the latest House and Senate Bills.

Navigating the Corporate Transparency Act: What ACCU Clients Need to Know


At ACCU Inc., we understand the importance of staying informed about legislative changes that can impact our clients. The recent enactment of the Corporate Transparency Act (CTA) by Congress in 2021 is a significant development, especially for community associations. This blog post aims to provide a comprehensive overview of the CTA and its implications for our clients.

Understanding the Corporate Transparency Act:

The CTA was established to enhance transparency in financial transactions, primarily to combat money laundering and terrorist financing. It applies to corporations, including non-profit entities like community associations that have fewer than 20 employees and less than $5 million in assets. The law mandates these organizations to report specific information to the Financial Crimes Enforcement Network (FINCEN).

Key Reporting Requirements:

Beginning January 1, 2024, for new entities and January 2025 for existing ones, community associations will be required to submit the following information to FINCEN:

  1. Business and legal names of board members, including birthdates, home addresses, and an identifying number from a driver’s license, state ID, or passport.
  2. Details of individuals with substantial control over financial reporting, including the same personal information.
  3. Prompt updates (within 30 days) on any changes, such as board member replacements or address changes.

Potential Impacts on Community Associations:

While the CTA is not primarily aimed at community associations, its broad scope means many such entities in Colorado may fall under its purview. This requires a proactive approach to compliance, including understanding who qualifies as an individual with substantial control within the association.

ACCU’s Role and Support:

As your trusted HOA management partner, ACCU is committed to guiding our clients through these new regulations. We can assist in identifying who within your association may need to report and help ensure timely and accurate compliance. Our team is equipped to offer support and resources to navigate these changes smoothly.

CAI’s Advocacy Efforts:

The Community Associations Institute (CAI) is actively advocating for the exemption of community associations from the CTA, citing that the Act was not intended to cover these entities. They are also pushing for a delay in the implementation of reporting requirements and confidentiality in the filings. ACCU supports these efforts and will keep our clients informed about any developments.


While the Corporate Transparency Act introduces new compliance obligations, ACCU is here to ensure that our clients are well-prepared and informed. We recognize the importance of adapting to legislative changes and are dedicated to providing the necessary support and guidance. Stay tuned for more updates and feel free to reach out to us for any specific concerns or questions about the CTA and its impact on your community.

H.R. 3700

H.R. 3700 was introduced for the purpose of reforming the process utilized by FHA to certify condominium associations. On July 29, 2016, H.R. 3700 was signed into law by President Obama. H.R. 3700 has been supported by CAI and considered a much needed change in the industry.Key changes set forth in H.R. 3700 include the following:

  • Requirement that FHA modify its certification requirements for condominium mortgage insurance to make recertification’s substantially less burdensome than original certifications.

  • The FHA must consider lengthening the time between certifications for approved properties and allowing information to be updated rather than resubmitted.

  • A HUD field office must make decisions regarding exemptions to current FHA commercial space requirements and must consider factors relating to the economy of the locality in which the project is located.

  • The FHA must issue guidance regarding the percentage of units that must be occupied by the owners (or sold to owners intending to meet such occupancy requirements) in order for a condominium to be eligible for FHA mortgage insurance.

Now that the bill is officially law, the FHA will begin its implementation, which will involve changes to FHA regulations and existing agency guidelines.

  • SB 1237 The provisions of the Colorado Common Interest Ownership Act (CCIOA) authorize the creation of common interest communities to be governed by unit owners’ or homeowners’ associations (HOAs). Currently, there are approximately 16,000 common interest communities or HOAs in Colorado. During the 2012 legislative session, the General Assembly considered one piece of legislation concerning records maintained by an HOA and access to such records. House Bill 12-1237, which takes effect January 1, 2013, identifies a list of the records that must be maintained by an HOA concerning the finances, board meeting minutes, and other affairs of a common interest community under CCIOA. This bill also allows homeowners to access these types of records.

  • HOUSE BILL 13-1276 Concerning limitations on the actions a unit owners’ association under the “Colorado Common Interest Ownership Act” may take against a unit owner with respect to the collection of debt owed to the unit owners’ association. The House Bill 13-1276 act takes effect January 1, 2014; except that, if a referendum petition is filed pursuant to section 1 (3) of article V of the state constitution against this act or an item, section, or part of this act within the ninety-day period after final adjournment of the general assembly, then the act, item, section, or part will not take effect unless approved by the people at the general election to be held in November 2014 and, in such case, will take effect on the date of the official declaration of the vote thereon by the governor.