FINCEN’s position unclear on HOA beneficial ownership (NV)

/ Owner - April 1, 2024

We continue our discussion on the Anti-Money Laundering/Corporate Transparency Act and how it will affect our HOAs in Nevada.  What is somewhat ambiguous is whether or not community managers will be deemed individuals with “substantial control,” as that term is defined in 31 C.F.R §1010.380(d)(1)(i). When reviewing the definition, it can be argued that, essentially, community managers do not have the authority to exercise any of the decisions or actions that are set forth in the above regulation    Read the article…………………………….

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