Are homeowners associations reporting companies?

It depends. Homeowners associations (HOAs) can take different forms. As with
any entity, if an HOA was not created by the filing of a document with a secretary
of state or similar office, then it is not a domestic reporting company. An
incorporated HOA or other HOA that was created by such a filing also may qualify
for an exemption from the reporting requirements. For example, HOAs recognized
by the IRS as section 501(c)(4) social welfare organizations (or that claim
such status and meet the requirements) may qualify for the tax-exempt entity
exemption. An incorporated HOA that is not a section 501(c)(4) organization,
however, may fall within the reporting company definition and therefore be
required to report BOI to FinCEN.
[Updated June 10, 2024]