Effective March 1, 2026, FinCEN’s Residential Real Estate Rule will impose streamlined reporting (the Real Estate Report) and recordkeeping requirements on certain persons involved in residential real estate closings and settlements (collectively, Reporting Persons). FinCEN published the Rule in the Federal Register on Aug. 29, 2024, and released related guidance, including a Fact Sheet and Frequently Asked Questions.

The Residential Real Estate Rule applies to non-financed transfers of residential real property to legal entities and trusts and does not apply to transfers to natural persons.

Although the Rule originally took effect Dec. 1, 2025, FinCEN issued exemptive relief extending the compliance date to March 1, 2026. The reporting requirements apply to reportable transfers that close on or after March 1, 2026.

Click here to read the full GT Alert.

Tags: FinCEN, GT Insight, real estate, residential real estate
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Photo of Marina Olman-Pal Marina Olman-Pal

Marina Olman-Pal, Co-Chair of the firm’s Financial, Regulatory & Compliance Practice, advises foreign and U.S. financial institutions on a broad range of regulatory matters including licensing, acquisitions, divestitures, compliance with Bank Secrecy Act (BSA)/anti-money laundering (AML) laws and regulations, and compliance with Office…

Marina Olman-Pal, Co-Chair of the firm’s Financial, Regulatory & Compliance Practice, advises foreign and U.S. financial institutions on a broad range of regulatory matters including licensing, acquisitions, divestitures, compliance with Bank Secrecy Act (BSA)/anti-money laundering (AML) laws and regulations, and compliance with Office of Foreign Assets Control (OFAC) sanctions programs. Marina counsels a wide range of companies in the financial services sector including, domestic and foreign banks, gaming companies, money services businesses including money transmitters, cryptocurrency businesses, Fintech companies and digital payment companies. Throughout her career, Marina has represented clients before U.S. regulators such as the Federal Reserve, OCC, FDIC, FinCEN, OFAC, the Florida Office of Financial Regulation and other state supervisory authorities. Marina also regularly develops anti-money laundering programs for a wide range of financial services businesses and non-financial services businesses including, U.S. and foreign companies active in industries such as real estate, hospitality, automotive and artificial intelligence, among many others.

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