FinCEN RRE Rule vs. BOI/CTA: Two Reporting Rules, Two Different Obligations

FinCEN now administers two separate reporting regimes that both involve beneficial ownership information: the Corporate Transparency Act (CTA) and its Beneficial Ownership Information (BOI) reporting requirements, and the Real Estate Reporting (RRE) rule under the Bank Secrecy Act. Both require disclosure of the real people behind legal entities. Both are administered by FinCEN. Both took effect within about a year of each other.

That is where the similarities end. The rules differ in who files, what triggers filing, what information is reported, where it is filed, and what the deadlines are. Confusing the two is easy. Getting them wrong creates compliance gaps. This guide breaks down the differences so you know exactly which obligation applies and when.

The CTA/BOI rule requires most legal entities formed or registered to do business in the United States to report their beneficial ownership information directly to FinCEN. This is a one-time filing (with updates when ownership changes) that applies to the entity itself, regardless of what the entity does. It covers LLCs, corporations, and similar entities.

The RRE rule requires reporting persons — typically title companies, escrow agents, or real estate attorneys — to file a Real Estate Report with FinCEN for each covered non-financed residential real estate transfer to a legal entity or trust. It is triggered by a specific transaction, not by the entity's existence.

In short: BOI is about who you are. RRE is about what you bought.

Under the CTA, the entity itself (or a third-party service on its behalf) files the BOI report. If you own an LLC, the filing obligation is yours. Your title company, attorney, or accountant has no obligation to file it for you (though some offer it as a paid service).

Under the RRE rule, the reporting person files the Real Estate Report. The reporting person is determined by a hierarchy in the rule — typically the person who closes or settles the transaction. In most cases, that is the title company or escrow agent. The buyer does not file the RRE report. The buyer's role is to provide the beneficial ownership information requested by the closing agent.

This distinction matters because the entity-buyer may have a BOI obligation AND be the subject of an RRE filing — but these are filed by different parties through different systems. Our title agents guide covers the reporting-person hierarchy in detail.

BOI filing is triggered by entity formation or registration. If you form an LLC in Delaware, you owe a BOI report within 90 days (for entities formed after January 1, 2024) or by the applicable deadline for existing entities. No transaction is required — the entity's existence is the trigger.

RRE filing is triggered by a specific real estate transaction: a non-financed transfer of residential real property to a legal entity or trust. If an LLC exists but never buys property, the RRE rule never applies to it. If the same LLC buys three properties in a year, each purchase may trigger a separate RRE filing.

Key difference: an entity with no real estate activity has a BOI obligation but no RRE obligation. A real estate transaction involving an individual buyer (not an entity) has no obligation under either rule.

BOI reports are filed through the Beneficial Ownership Information Report (BOIR) system at boiefiling.fincen.gov. It is a dedicated FinCEN portal for CTA compliance.

RRE reports are filed through the BSA E-Filing system — the same platform used for Currency Transaction Reports, Suspicious Activity Reports, and other BSA filings. If you already file CTRs or SARs, you use the same account.

These are completely separate systems with separate accounts, separate forms, and separate submission processes. Filing a BOI report does not interact with BSA E-Filing in any way, and vice versa. For a walkthrough of the BSA E-Filing process for RRE reports, see our filing guide.

The RRE rule took effect on March 1, 2026, as scheduled. It applies to all covered transactions closing on or after that date. The first filing deadlines arrive on April 30, 2026. Legal challenges have failed, and the rule is fully operational. See our lawsuits analysis for the full background.

The CTA/BOI rule has had a more complicated path. After multiple court challenges and injunctions, FinCEN issued a final rule in March 2025 exempting all domestic entities from BOI reporting requirements. As of 2026, only entities formed under foreign law that are registered to do business in the United States are required to file BOI reports. Domestic LLCs and corporations are currently exempt from CTA/BOI reporting.

This means that as of today, a domestic LLC buying property triggers an RRE filing by the title company but does not trigger a BOI filing by the LLC itself. A foreign entity registered in the U.S. and buying property could trigger both.

The confusion is understandable. Both rules involve FinCEN. Both deal with beneficial ownership. Both require names, dates of birth, addresses, and identification numbers for the people behind entities. Many real estate professionals first heard about "FinCEN beneficial ownership reporting" in the context of the CTA and assumed the RRE rule was the same thing.

The confusion creates real compliance risks. A title company that assumes its buyer's BOI filing satisfies the RRE obligation is wrong — and is not filing the required Real Estate Report. A buyer who provides BOI information to FinCEN and assumes the title company has what it needs is also wrong — the title company needs the information directly from the buyer for the RRE report.

When in doubt about whether a specific transaction triggers RRE reporting, use our free checker. It evaluates the transaction against the RRE rule specifically and gives you a clear determination.

The scenario where both rules apply: a foreign-formed entity registered to do business in the U.S. purchases residential real property without financing. The entity owes a BOI report under the CTA (because it is a foreign reporting company), and the title company owes a Real Estate Report under the RRE rule (because the transaction is a covered non-financed transfer).

In this case, the entity files its BOI report through BOIR, and the title company files its RRE report through BSA E-Filing. The information overlaps significantly — both require beneficial owner names, dates of birth, and identification numbers — but the filings are independent. Neither substitutes for the other.

For domestic entities (currently exempt from CTA/BOI), only the RRE rule applies. For our beneficial ownership certification guide, we walk through exactly what information the title company needs to collect from the entity for the RRE report.

Who files: CTA/BOI — the entity itself. RRE — the title company or closing agent. What triggers filing: CTA/BOI — entity formation or registration. RRE — a covered real estate transaction. Filing system: CTA/BOI — BOIR (boiefiling.fincen.gov). RRE — BSA E-Filing.

Deadline: CTA/BOI — 90 days from formation (new entities) or applicable deadline (existing). RRE — later of 30 days after closing or end of next month. Current scope: CTA/BOI — foreign entities only (domestic exempt since March 2025). RRE — all covered transactions since March 1, 2026. Penalties: both carry civil penalties under their respective statutes, with willful violations subject to criminal prosecution.

Still have questions about your obligations? Start with the checker for your next transaction, or explore our Filing Kit and Agency Pack for complete compliance templates covering the RRE rule end to end.