Beneficial Ownership Information (BOI Reporting): Policy Issue

Overview

In 2021, Congress passed the Corporate Transparency Act. The law established a new beneficial ownership reporting rule to prevent bad actors from hiding assets or profiting through shell companies and opaque structures. Originally, both domestic and foreign companies were subject to Beneficial Ownership Information (BOI) reporting requirements based on the Treasury Department’s Financial Crimes Enforcement Network’s (FinCEN) reporting rule. On March 26, 2025, FinCEN issued an interim final rule removing all beneficial ownership reporting requirements for U.S. companies and persons, while maintaining reporting requirements for foreign companies.

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Industry Position

The National Apartment Association (NAA) supports FinCEN's exemption of U.S. companies and persons from BOI reporting requirements and urges the Trump Administration and Treasury Department to ask Congress to enact permanent changes to codify the narrowed rule. While NAA supports the goal of preventing financial crimes, the original framework imposed untenable reporting requirements and unnecessarily captured many law-abiding small businesses, including those in the rental housing industry.

As an Owner or Operator, How Does this Affect My Business?

Had the original, expansive rule gone into effect, many U.S. housing providers, especially Independent Rental Owners (IROs) and mid-sized providers, would have faced significant compliance obligations, including collecting and reporting detailed ownership information. The interim final rule ensures that these requirements are eliminated domestically, reducing additional administrative burden and cost.

However, millions of businesses have already submitted BOI data to FinCEN under the original rule. With the revised requirements, FinCEN should delete all records from entities that are no longer subject to reporting to protect privacy and reduce unnecessary compliance burdens.

For any compliance concerns, housing providers are encouraged to consult with qualified legal counsel.

Contact Information

To learn more about this issue, please contact NAA's Public Policy team.