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They Don’t Want Our Fines, They Want Our Cooperation

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When discussing the historic $3 billion fine imposed on TD Bank for conspiracy to violate the Bank Secrecy Act, U.S. Attorney General Merrick Garland stated, “TD Bank created an environment that allowed financial crime to flourish. By making its services convenient for criminals, it became one.” FinCEN, one of the key agencies involved in prosecuting and enforcing this penalty, is the same organization requiring HOAs to submit a Beneficial Ownership Information report.

The Corporate Transparency Act and the filing requirement for HOAs are obligations that must be addressed.

To be clear, FinCEN doesn’t necessarily suspect HOA boards are engaged in criminal activities. Instead, they attempt to target bad actors who pose as legitimate HOAs and board members. But they cannot identify these imposters without our help.

Imagine you manage the Happy Townhomes Association, a thriving community with a board of five officers. Now, consider that a bad actor creates a fake entity called “Happy Townhomes HOA, Inc.”—legitimately registered with the intent to mimic your actual HOA. This fraudulent organization could make large deposits and transfers, claiming they are collecting dues or paying contractors for non-existent services. If you were a law enforcement agent investigating these transactions, how could you distinguish between the real and the fake HOA just by looking at the paperwork? You wouldn’t be able to.

For law enforcement, it’s challenging to tell the difference between a legitimate HOA with actual board members and a criminal organization pretending to be one. HOA information is often fragmented, difficult to verify, and spread across multiple sources. FinCEN needs our help to create a centralized database of verified HOAs and board members. With a verified database of actual HOAs and board members in place, law enforcement can more easily detect and stop imposters who use HOA identities for financial crimes. FinCEN is committed to identifying financial criminals, and by complying with these requirements, we make it much harder for criminals to hide from law enforcement.

Remember that the information submitted to FinCen is the same data banks already require to authorize board members to open accounts and sign financial documents. With the right tool, compliance is easy and helps to keep our communities and industry distant from bad actors and criminals.

Don’t wait until it’s too late—ensure your HOA is compliant today.

hoacta.app: A CTA Compliance Solution just for HOAs

A group of CAI members and industry experts developed hoacta.app to streamline the filing process, ensure compliance, and protect from bad actors. Founded and operated by industry professionals, including PCAMs, National BP Council members, and a CAI Chapter President, hoacta.app offers a comprehensive, secure solution for CAT compliance specifically for HOAs.

World-Class Security and Privacy Compliance

Hoacta.app uses high-grade encryption technology and dynamic code updates to ensure data security. It complies with federal and international standards, including:

  • GDPR (General Data Protection Regulation)
  • CCPA (California Consumer Privacy Act)
  • ISO/IEC 27001, and others

Fraud-Proof Filing

Hoacta.app utilizes optical character recognition (OCR) technology, artificial intelligence, and government record integrations to verify ID validity. The platform employs biometric selfie scans to ensure that only rightful ID owners submit information.

Automated Communication

The system automatically reminds board members when their IDs are about to expire and prompts them to update their information without restarting the entire filing process. To start, simply enter the HOA’s address, Tax ID (or EIN), and board member name and contact, and the system manages the rest.

With one year of unlimited updates, edits, and revisions included, hoacta.app keeps HOAs compliant year-round–guaranteed.

Management Dashboards: Stay Informed

The platform’s management dashboards allow managers to monitor the progress of each report. You’ll always know which tasks are complete and what still needs attention, ensuring your HOA stays on track for compliance.

Filing with hoacta.app is guaranteed and starts at under $200 with bulk pricing. Contact an hoacta.app rep today today.

Ramona Acosta

Ramona Acosta, PCAM, hoacta.app Co-Founder - Ms. Acosta brings nearly 20 years of experience in the HOA industry, holding top CAI designations (CMCA, AMS, PCAM) and expertise in California HOA law. Her leadership roles in CAI, combined with extensive collaboration with boards, vendors, and managers, provided valuable insights that shaped the development of hoacta.app