ALERT: New Details On The FinCEN Ruling

Due to a federal court ruling on March 19, 2026, the FinCEN Residential Real Estate (RRE) reporting requirements – which took effect on March 1 – have been vacated nationwide and are currently not being enforced.

Learn about Land Title

Land Title will not require impacted parties to provide any new information under the FinCEN ruling as long as the reporting pause is in place.

This is a rapidly shifting landscape and Land Title will continue to monitor the issues closely.

FinCEN Overview

On March 1, 2026, FinCEN expanded its ruling nationwide. Previously, to determine whether your transaction fell under this newly expanded reporting rule, below were the conditions:

–At least one of the buyers is a legal entity, including LLCs, corporations, partnerships, trusts, or similar
entities.

–The transaction involves residential real estate, including single-family homes, townhomes, condos, co-ops,
small multi-family properties (up to 4 units), mixed-use properties, and vacant land intended for a 1-to-4
residential units.

–The purchase is in cash or does not involve financing from a traditional lending institution.

We understand that this new reporting requirement presented a change to our closing process in that our team
members needed to collect additional information about both the buyer and the seller.

Previously, if a transaction meets all the specified criteria, the designated reporting party must file a Real Estate Report with FinCEN. Parties to impacted transactions must provide certain information before closing and need to understand that failure to provide such information in a timely manner may result in a delay or inability to close or issue a policy.