Not to change the subject (to get it back on topic), but I must agree with much of what the "community associations" lawsuit claims.  HOAs are run by volunteers, who may not want to reveal their personal data to other board members and a management company. And there is frequent turnover.  Fincen could have made exceptions that cover these organizations -- especially since some of them are old enough to have 501(c) status, but others are not. (As I read it, the new Code section is 528.)  

But why wait until just a few months before the deadline? It's not like they haven't seen this coming since January 2021.  "It is better to curse the darkness, than to light one candle," I suppose.