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.
Fact pattern
Riverside Properties LLC purchases a single-family home in Austin, Texas for $825,000. The LLC obtains a $660,000 mortgage from JPMorgan Chase, a federally regulated bank. The loan is secured by the property being purchased, with a standard deed of trust recorded at closing. The LLC puts down $165,000 in cash.
Analysis
Even though the buyer is an entity (LLC) and the property is residential (single-family home), the financing exclusion likely removes this transaction from scope. The mortgage comes from JPMorgan Chase, which is a BSA-regulated financial institution subject to anti-money-laundering program requirements and suspicious activity reporting obligations.
The key requirement is that the loan must be secured by the transferred property. Here, the deed of trust is recorded against the purchased home at closing, satisfying that condition. Because the bank is already required to perform customer due diligence, verify the borrower's identity, and file SARs if the transaction looks suspicious, the anti-money-laundering oversight already exists for this transaction.
The cash down payment ($165,000) does not change the analysis. The exclusion applies when the transfer involves qualifying financing, even if part of the purchase price is paid in cash. The relevant question is whether a BSA-regulated lender is extending credit secured by the property, not whether 100% of the price is financed.
Key factors
- Mortgage from a BSA-regulated bank (JPMorgan Chase)
- Loan is secured by the property being purchased (deed of trust recorded)
- The bank already performs anti-money-laundering due diligence on the borrower
- Partial cash down payment does not defeat the financing exclusion
- Document the determination and retain lender verification in your file
Next step
Run the transaction through the checker to capture a determination PDF and keep your file trail complete.
Related scenarios
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.
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.