Real Estate Law Services

NOTE: As of late March, 2026, reporting requirements are temporarily on hold pending resolution of a court-ordered injunction.

FINCEN: What is reported?

Effective March 1, 2026, FinCEN’s Residential Real Estate (RRE) Rulemandates that certain real estate professionals report "non-financed" transfers of residential property to legal entities or trusts. A transaction is reportable if it involves residential real estate (1–4 family units, condos, or vacant land for such use), is "non-financed" (lacking a mortgage from a lender with anti-money laundering (AML)obligations), and the buyer is an entity like an LLC or a trust. Responsibility for filing the Real Estate Report falls on a "reporting person"—typically the settlement agent, title insurance agent, or closing attorney—determined by a seven-tier reporting cascade. Reports must include the identity of the beneficial owners of the buying entity and details of the transaction, and they are due by the later of 30 days after closing or the last day of the following month. 

What Type of Entities are Subject to the Reporting Rule?

A transfer is reportable if the buyer is a transferee entity or transferee trust, defined as follows: 

• Transferee Entities: Includes any legal person      other than an individual or a trust, such as corporations,      limited liability companies (LLCs), partnerships, estates, and associations.
• Transferee Trusts: Broadly includes most      domestic and foreign trusts     or similar legal arrangements, regardless of whether title is held in the name of the trust or the trustee.