FinCEN Asks for More Comments on its Real Estate Reporting Form

FinCEN announced that it is again seeking comments, due by July 7, on an updated draft of the reporting form that will be used to report information about certain residential real estate transfers under the Residential Real Estate Rule finalized by FinCEN late last year.

​In April 2024, the CLTA submitted comments to FinCEN questioning the wisdom of expanding FinCEN’s existing reporting rules, and that the expense and burden of reporting seemed to far outweigh any benefit. In January 2025, CLTA submitted an additional round of comments, calling on the agency to, at a minimum, significantly narrow the scope of information required to be collected and reported via the proposed form, and asking it to consider taking a more measured, or phased, approach to the expansion of the information collection and reporting under the rule.

FinCEN has stated that it had received comments expressing concern with the burden of completing the proposed RER, which contains a total of 111 fields. FinCEN now states that it intends to make an external sandbox environment available before December 1, 2025, to allow reporting parties to test batch filing of Real Estate Reports (RERs). Additionally, FinCEN plans to offer webinars on filing procedures, including batch filing.