Overview

• The effective date shifts from Dec. 1, 2025 to March 1, 2026, pausing new reporting under the Residential Real Estate Transfers rule.
• An exemptive order covers all reporting persons from Sept. 30 through March 1, 2026, while existing Geographic Targeting Orders remain in force.
• The regulation targets all-cash transfers to entities or trusts and requires collection of personal identifiers, payment details, and beneficial ownership information, including for minors.
• Fidelity National Financial’s lawsuit challenging the rule continues, with motions for a preliminary injunction and summary judgment and a supportive amicus brief from the American Land Title Association.
• FinCEN released a “for reference” real estate report form and industry leaders said the delay acknowledges compliance burdens, noting ALTA members could file over half of the expected 800,000–850,000 reports.