FinCEN Postpones Residential Real Estate Reporting Requirement Until March 2026

FinCEN announced today that the reporting requirements for the “Anti-Money Laundering Regulations for Residential Real Estate Transfers Rule” (RRE Rule) have been postponed until March 1, 2026. The previous deadline was Dec. 1, 2025, for a new anti-money laundering rule that requires reporting for specific all-cash residential real estate transactions involving legal entities and trusts to the U.S. Department of Treasury’s Financial Crimes Enforcement Network.

In a press release, FinCEN officials acknowledged that the agency is postponing the deadline to provide the real estate industry with more time to comply, to reduce business burden, and to ensure effective regulation. FinCEN has issued a temporary order granting exemptive relief from the reporting requirements.

In August, FinCEN introduced the Anti-Money Laundering Regulations for Residential Real Estate Transfers Rule, which does not apply to transfers made directly to individuals. It is triggered only when the transferee is a legal entity (such as a corporation, LLC, partnership, or estate) or a trust. All-cash and non-bank financed transactions are the primary focus of the new rule as they present higher risks for money laundering.

The new rule directly impacts a range of real estate professionals and businesses involved in closings and settlements, including settlement agents, title insurance companies and agents, escrow agents, attorneys involved in closings, and other professionals performing specified functions in the transfer process.

Real estate professionals involved in closings must identify the reporting party, collect detailed beneficial ownership information, and file reports within 30–60 days. FinCEN has published the Real Estate Report Form that now must be submitted by March 1, 2026. FinCEN has also published a fact sheet and FAQs on the new rule.

Read our alert published last month that details various requirements within the new rule such as what constitutes a reportable transfer, who is the reporting person, what must be disclosed, and what transactions are exempt and not reportable.

All professionals involved in closings and settlements of residential real estate to entities or trusts should familiarize themselves with the rules, review their transaction processes, update closing documentation, assess their exposure, and prepare for reporting and recordkeeping obligations to ensure compliance by the new effective date of March 1, 2026.

About Our Authors

April Smith serves as the Real Estate Team Leader at Adams & Reese, and she is a Partner in the Mobile office. For 20 years, April has represented TIMOs, REITs, financial institutions, businesses, and individuals in a wide range of transactions, including timberland and commercial property acquisitions and sales, timberland and commercial financing, mergers and acquisitions, and business sales.

Sean Buckley is a member of the Adams & Reese Corporate Services Practice Group and a Partner in the Houston office. Sean advises clients on a wide array of corporate matters, including the purchase and sale of equity and assets, and in a diverse array of industries, including real estate transactions, entity selection and formation, corporate governance, and franchise opportunity matters.