New Details On The FinCEN Ruling
Due to a federal court ruling on March 19, 2026, the FinCEN Residential Real Estate (RRE) reporting requirements, which originally took effect on March 1, have been vacated nationwide and are currently not being enforced.
New Details On The FinCEN Ruling
Due to a federal court ruling on March 19, 2026, the FinCEN Residential Real Estate (RRE) reporting requirements, which originally took effect on March 1, have been vacated nationwide and are currently not being enforced.
What This Means for Your Closing
Meridian Title will not require impacted parties to provide any new information under the FinCEN ruling as long as this reporting pause is in place.
This is a rapidly shifting landscape. Meridian Title will continue to monitor the legal and regulatory issues closely to keep our clients informed and ensure a smooth closing process.
FinCEN Overview and Previous Requirements
On March 1, 2026, FinCEN expanded its reporting rule nationwide. Previously, to determine whether your transaction fell under this newly expanded reporting rule, the following conditions had to be met:
Entity Buyer: At least one of the buyers is a legal entity, including LLCs, corporations, partnerships, trusts, or similar entities.
Property Type: The transaction involves residential real estate, including single-family homes, townhomes, condos, co-ops, small multi-family properties (up to 4 units), mixed-use properties, and vacant land intended for 1 to 4 residential units.
Financing Type: The purchase is in cash or does not involve financing from a traditional lending institution.
We understand that this new reporting requirement presented a change to our closing process in that our team members needed to collect additional information about both the buyer and the seller.
Previously, if a transaction met all the specified criteria, the designated reporting party was required to file a Real Estate Report with FinCEN. Parties to impacted transactions had to provide certain information before closing and needed to understand that failure to provide such information in a timely manner could result in a delay or inability to close or issue a title policy.
FinCEN Overview and Previous Requirements
On March 1, 2026, FinCEN expanded its reporting rule nationwide. Previously, to determine whether your transaction fell under this newly expanded reporting rule, the following conditions had to be met:
Entity Buyer: At least one of the buyers is a legal entity, including LLCs, corporations, partnerships, trusts, or similar entities.
Property Type: The transaction involves residential real estate, including single-family homes, townhomes, condos, co-ops, small multi-family properties (up to 4 units), mixed-use properties, and vacant land intended for 1 to 4 residential units.
Financing Type: The purchase is in cash or does not involve financing from a traditional lending institution.
We understand that this new reporting requirement presented a change to our closing process in that our team members needed to collect additional information about both the buyer and the seller.
Previously, if a transaction met all the specified criteria, the designated reporting party was required to file a Real Estate Report with FinCEN. Parties to impacted transactions had to provide certain information before closing and needed to understand that failure to provide such information in a timely manner could result in a delay or inability to close or issue a title policy.
Rule for Residential Transactions
Basics About the FinCEN Ruling
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