March 1, 2026
Effective Date
$0
Minimum Price Threshold
800K+
Est. Annual Reports
What Triggers a Report? The 4-Part Test
A real estate transaction must be reported to FinCEN only if it meets all four of the following criteria.
- 🏠
Residential Property
Includes 1-4 family homes, condos, co-ops, and vacant land.
- 💸
Non-Financed Transaction
All-cash deals or those with private financing (no bank involved).
- 💼
Transferee is an Entity or Trust
The buyer is an LLC, corporation, partnership, or trust.
- 📜
No Exemption Applies
Transfer is not due to death, divorce, or bankruptcy.
Who is Responsible for Reporting?
The rule establishes a "reporting cascade" to identify the single party responsible for filing.
1. Closing or Settlement Agent
2. Preparer of Settlement Statement
3. Filer of the Deed
4. Title Insurance Underwriter
Operational Impact
Estimated Compliance Costs
FinCEN projects significant financial impact due to training and new procedures.
Key Challenges
- 📋 Data Acquisition & Verification
- 🔒 Secure Handling of Sensitive Info
- ⏱ Tight Reporting Deadlines
- ⚠ Severe Penalties for Non-Compliance
✨ AI Compliance Assistant
Utilize our AI assistant to clarify compliance jargon or check reportability.
Jargon Explainer ✨
Reportability Checker ✨
Legal and Legislative Headwinds
Judicial Challenges
Lawsuits have been filed arguing FinCEN exceeded its authority under the Bank Secrecy Act.
Congressional Challenges
Joint resolutions have been introduced in Congress to disapprove of the rule.