Is a Mixed Financing Transfer Reportable?

This is where the analysis gets fact-sensitive. The credit union's $500,000 mortgage appears to satisfy the financing exclusion: it comes from a BSA-regulated institution and is secured by the property being transferred. But the $475,000 private loan does not clearly qualify. It comes from a private individual (likely not BSA-regulated) and is secured by a different property, not the one being transferred.

The question is whether the existence of qualifying financing for part of the purchase price is sufficient, or whether the non-qualifying financing component brings the transaction back into scope. FinCEN's guidance focuses on whether the transfer involves an extension of credit from a BSA-regulated lender secured by the transferred property. When a significant portion of the consideration comes from non-qualifying sources, the safest approach is to treat the transaction as potentially reportable until you have clear guidance or legal advice.

Teams should not try to force this into a clean category. Mixed financing structures are the scenarios most likely to produce incorrect determinations when handled by staff without specific training. Document all financing sources, flag the complexity, and escalate for review before assigning a final reportability status.