As of March 1, 2026, the Financial Crimes Enforcement Network (FinCEN) requires reporting on certain non-financed residential real estate transfers under a new federal rule codified at 31 CFR § 1031.320. This page explains what the rule covers, who it affects, and what it means for your transaction.

What the Rule Requires

Under the Bank Secrecy Act, FinCEN now requires settlement agents — including title companies and closing attorneys — to file a Real Estate Report for certain residential property transfers. The rule targets non-financed transactions (commonly called "all-cash" purchases) where the buyer is a legal entity or trust. There is no minimum purchase price; if a transaction meets the criteria, it is reportable regardless of amount.

Non-financed means the purchase does not involve a mortgage or loan from a financial institution that is already subject to federal anti-money laundering and suspicious activity reporting obligations. Transactions funded through private lending or hard-money loans may also trigger reporting.

Who It Affects

The rule applies when a residential property is purchased by a legal entity — such as an LLC, corporation, or partnership — or by a trust, using non-traditional or non-institutional financing. It covers one-to-four unit residential properties, individual condominium and cooperative units, and vacant land where the buyer intends to build a residential structure.

Most individual homebuyers financing their purchase through a bank or mortgage lender are not affected. The rule is designed to increase transparency in transactions where traditional lender-based reporting does not already exist.

What It Replaces

Before this rule, FinCEN used Geographic Targeting Orders (GTOs) to require similar reporting, but only in specific metropolitan areas and only above certain dollar thresholds. The new rule replaces the GTOs with a single, nationwide standard. Reporting is now required for qualifying transactions in every state, with no minimum price.

What This Means for Clients

If your transaction falls under this rule, you may be asked to provide additional information during the closing process. This is a standard federal compliance requirement — not an indication of any problem with your transaction. Title companies and closing attorneys across the country are following the same procedures.

Meridian Title handles the reporting process as part of our closing services. We collect the required information, prepare the Real Estate Report, and file it electronically with FinCEN within the required timeframe. There is nothing additional you need to file on your own.

Information Collected

When a transaction requires reporting, FinCEN mandates that the Real Estate Report include:

The legal name, address, and tax identification number of the purchasing entity or trust
Beneficial ownership information — the individuals who ultimately own or control the entity or trust, including their name, date of birth, address, and identification
The seller's legal name, address, and tax identification number
Property details including address and legal description
Transaction details including total consideration, method of payment, and sources of funds

For entity buyers, beneficial owners include anyone who exercises substantial control or holds at least a 25% ownership interest. For trusts, this includes trustees, grantors of revocable trusts, and certain beneficiaries. All information is submitted securely to FinCEN and is not part of the public record.

Meridian Title's Compliance

Meridian Title Company is fully prepared to comply with the FinCEN Residential Real Estate Rule. Our team has implemented the necessary procedures to identify reportable transactions, collect required information, and file Real Estate Reports accurately and on time. If your closing involves a reportable transaction, we will walk you through the process and answer any questions along the way.

Important Notice

This information is for educational purposes only and is not legal advice. The FinCEN Residential Real Estate Rule involves specific criteria and limited exemptions that may apply differently depending on the circumstances of your transaction. Consult your attorney for guidance on your specific situation.

FinCEN Reporting Rule

Overview