The Latest Policy News on FinCEN RRE
March 20, 2026
Following a federal court decision on March 19, 2026, vacating FinCEN's Residential Real Estate Reporting Rule, FinCEN issued guidance confirming that reporting persons are not currently required to file reports under the rule.
What this means:
- FinCEN has acknowledged the court’s ruling and is not requiring compliance with reporting obligations at this time.
- This reflects the current regulatory posture but may change depending on future legal or administrative developments.
While this guidance provides near-term clarity, uncertainty remains. Future action by FinCEN or the courts could reinstate or modify reporting requirements.
Background
Since January 2016, the Financial Crimes Enforcement Network (FinCEN), required title companies to collect and report beneficial ownership information on certain real estate transactions. These Geographic Targeting Orders apply to all title insurers, their subsidiaries and agents of (“Covered Business”).
ALTA's Position
ALTA is concerned about FinCEN’s underestimated expense the rule will cost the industry. According to FinCEN, the rule will cost the industry $453.9 million annually ($476.2 million in the first year. This equates to almost $500 per real estate report based on FinCEN’s estimate that 850,000 reports will be filed annually. ALTA’s letter said these amounts are excessive both in total and on a per-transaction basis.
For more ALTA Resources, visit alta.org/fincen.
FinCEN Resources
FinCEN Geographical Targeting Orders
ALTA's Comment Letter to FinCEN
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