Regarding who must report Beneficial Owner Information for an incorporated HOA, FINCEN's FAQ has this to say:
D. 13. Who is the beneficial owner of a homeowners association?

A homeowners association (HOA) that meets the reporting company definition and does not qualify for any exemptions must report its beneficial owner(s). A beneficial owner is any individual who, directly or indirectly, exercises substantial control over a reporting company, or owns or controls at least 25 percent of the ownership interests of a reporting company.

There may be instances in which no individuals own or control at least 25 percent of the ownership interests of an HOA that is a reporting company. However, FinCEN expects that at least one individual exercises substantial control over each reporting company. Individuals who meet one of the following criteria are considered to exercise substantial control over the HOA:

the individual is a senior officer;
the individual has authority to appoint or remove certain officers or a majority of directors of the HOA;
the individual is an important decision-maker; or
the individual has any other form of substantial control over the HOA.

[Issued April 18, 2024]