FinCEN Final Rule: New Residential Real Estate BOI Reporting Requirements, Compliance Obligations, Industry Impact

Please join us for a continuing legal education (CLE) webinar that will guide practitioners through the U.S. Department of the Treasury's Financial Crimes Enforcement Network's (FinCEN) long-awaited final rule to increase transparency in non-financed residential real estate transactions that will significantly impact covered real estate entities with extensive new reporting obligations. The panel will address who is covered by the new rule, the reporting requirements and best practices to prepare for compliance.

In its ongoing efforts to combat and deter money laundering, FinCEN recently issued its long-awaited final rule, effective Dec. 1, 2025, that extends anti-money laundering reporting requirements to the residential real estate sector nationwide and increases the transparency of certain non-financed real estate transactions.

The final rule covers businesses, including attorneys, performing specified closing or settlement functions for the non-financed sale or transfer of residential real property to a legal entity or trust. The final rule requires a reporting person, as identified in a reporting cascade, to collect and report certain information related to the transaction to FinCEN in a Real Estate Report. The Real Estate Report is more extensive than the Beneficial Ownership Information (BOI) Report filed under the Corporate Transparency Act (CTA), although it will contain some of the same information.

Topics:

• Who are required reporting entities? Reporting persons?
• What information will be required to be reported?
• Who are the reportable transferees and to what residential real estate transactions does the final rule apply?
• What interaction does the final rule have with the CTA?
• What steps should counsel and their clients take now to prepare for compliance?