What Changed
Non-financed transfers of covered residential property to legal entities and trusts now trigger a structured reporting analysis path.
FinCEN Residential Real Estate Rule
Make reportability decisions fast, then execute filing prep with confidence.
Built for title and escrow professionals. Determine reportability in minutes, capture a defensible PDF record, and move into structured filing prep workflows for the 111-field reporting scope.
15 days until March 1, 2026 enforcement begins.
Who Must File
One reporting person is selected through a seven-tier cascade, with designation agreements available for controlled reassignment.
Why Process Matters
The largest operational risk is inconsistent execution. Standardized determination records and deadline tracking reduce avoidable exposure.
How it works
A practical workflow, not a black box
1
Run the checker
Answer four guided questions and get a rules-based outcome with citation context.
2
Email your determination PDF
Capture the result in a shareable report record with explicit user consent.
3
Use filing templates
Choose the product tier that matches your team and implement standardized execution.
Learning center
Featured articles
12 min read
The FinCEN RRE Rule: Why It Exists, What It Requires, and What It Means for Title Agents
The real story behind the rule: shell companies, laundered billions, and why title agents are now on the front line of anti-money-laundering enforcement.
8 min read
Is This Closing Reportable? Four Questions That Tell You
A plain-English walkthrough of the four-question test that determines whether a closing triggers FinCEN reporting, with real examples for each outcome.
7 min read
RRE Penalties: What Actually Happens If You Don't File
Specific dollar amounts, criminal exposure, and the difference between an honest mistake and a pattern that gets you in real trouble.
Scenario analysis
Applied examples
Likely Reportable
Is a Cash Condo Sale to an LLC Reportable?
An LLC buys a condo with cash and no bank mortgage. This is the textbook pattern the rule was designed to catch.
Likely Not Reportable
Is a Bank-Financed Home Purchase by an LLC Reportable?
An LLC buys a house with a bank mortgage. The financing exclusion takes this out of scope because the bank is already doing the compliance work.
Review Recommended
Is a Mixed Financing Transfer Reportable?
A trust buys property with both a bank loan and private financing. Mixed financing structures need careful analysis because the details matter.
Products
Your closing is reportable. Now what?
The free checker tells you if a transfer is reportable. These kits give you every template, form, and checklist you need to actually handle it.
For individual closers
Filing Kit
$49
one-time · 9 templates & tools
Everything one closer needs to handle reportable files from screening through filing and 5-year retention.
- ✓ Transaction screening worksheet
- ✓ Buyer + seller collection forms
- ✓ Beneficial ownership certification form
- ✓ Designation agreement template
- ✓ 111-field checklist + deadline & retention tracker
For multi-person offices
Agency Pack
$149
one-time · 15 templates & tools
Everything in Filing Kit plus training, QA workflows, compliance policies, and client communication templates.
- ✓ All 9 Filing Kit items
- ✓ Staff training guide (with sign-off)
- ✓ Compliance policy & role matrix
- ✓ Manager QA checklist + monthly review
- ✓ 4 client communication templates
Compare all deliverables
vs. $120–$200/report for outsourced filing services
Official sources
Primary references
- FinCEN RRE Program Page
Primary portal for rule notices, guidance, and updates.
- FinCEN RRE FAQs
Official answers to common implementation questions.
- RRE Filing Instructions (PDF)
Field-by-field instructions for completing the Real Estate Report.
- BSA E-Filing Portal
Where you submit the Real Estate Report electronically.
- Federal Register Final Rule
The full text of the final rule as published in the Federal Register on August 28, 2024.
FAQ preview
Quick answers
What is a reportable transfer?
A transfer of residential real property (houses, condos, townhouses, co-ops, or 1-4 unit buildings) to a legal entity (LLC, corporation, partnership) or trust, where the purchase is not financed by a mortgage from a BSA-regulated bank or credit union, and no exemption applies. In plain terms: if a shell company buys a house with cash and no bank is involved, someone has to report it to FinCEN.
Why does this rule exist?
For decades, all-cash real estate purchases through shell companies were one of the easiest ways to launder money in the United States. When a bank issues a mortgage, they run anti-money-laundering checks. But when an anonymous LLC buys a $5 million condo with a wire transfer, nobody was required to ask who controls the LLC or where the money came from. FinCEN found $53.7 billion in suspicious real estate activity between 2020-2024. This rule closes that gap by requiring disclosure of the real humans behind entity purchases.
Who is the reporting person?
The first person in a seven-tier cascade who performed a specific function in the closing. The tiers are, in order: (1) closing/settlement agent, (2) settlement statement preparer, (3) deed filer, (4) title insurance underwriter, (5) largest fund disburser, (6) title evaluator, (7) deed preparer. In most residential closings, the title company is the settlement agent at Tier 1. Filing responsibility can be reassigned to another cascade participant through a written designation agreement, but only for that specific transaction.
Ready to run your next file?