Originally scheduled for December 1, 2025, the start date for certain professionals involved in real estate closing and settlements to submit reports to Financial Crimes Enforcement Network (FINCEN) regarding certain non-finance transfers of residential real estate to legal entities or trusts (“transferees”) has been delayed to March 1, 2026.
Typically, the reporting obligation will be on title companies, but clients will have to be involved in gathering the information that the title companies will need to include in their report, which consists of:
Any non-financed transfers of residential real estate not subject to exemption must be reported.
Additional Assistance
For more information, please contact a member of our Real Estate Industry Team or the Phillips Lytle attorney with whom you have a relationship.
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