FinCEN Publishes New Frequently Asked Questions in Advance of the March 1 Effective Date

With new information collection and reporting regulations set to go into effect on March 1, 2026, FinCEN published about an additional 100 frequently asked questions (FAQs) relating to its Residential Real Estate Rule. 

​The agency said the updated list supersedes any prior FAQs that have been issued, and that it anticipates publishing further guidance in the future. 
 
The Anti-Money Laundering in Real Estate Rule (Rule) will impact all CLTA members handling sale transactions involving buyer entities or trusts without involving FDIC-insured lenders. The Rule applies nationwide, has no purchase price thresholds, offers limited transactional exemptions, and mandates the collection and reporting of significant amounts of information. 

If you have not already done so, CLTA members are encouraged to begin discussions and sharing information with one another, as well as real estate agents, buyers, sellers, and other interested parties.  

CLTA members have been strongly encouraged to check out the CLTA Titlecasts for more information about the FinCEN Rule.
  

• Episode 34: FinCEN, p1 - Overview of the FinCEN Final Residential Real Estate Rule
• Episode 35: FinCEN, p2 - CLTA’s Considerations for FinCEN Implementation
• Episode 38:  FinCEN, p3 – Examining the Definition of “Residential” and “Non-Financed” Under the New Rule
• Episode 39:  FinCEN, p4 – Beneficial Ownership
• Episode 40:  FinCEN, p5 – Exempt Transactions
• Episode 42:  FinCEN, p6 - Operational Strategy for Staff / Customers and Penalites
• Episode 43:  FinCEN, p7 – Information Collection 

As always, CLTA Titlecast episodes are available to Regular, Associate and Affiliate members as a direct membership benefit. Regular and Associate members include anyone employed by a CLTA member title company. Affiliate members are those that have joined from affiliated industries that work closely with title companies.