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🐐🚨 The FinCEN Rule Delayed! What Changed, Why It Matters, and How to Actually Get Ready

FinCEN Postpones AML Rule—Here’s What That Means for Your Workflow (And Sanity) Plus Some New Resources to Make This SO Much Easier!

Cheryl.wtf's avatar
Cheryl.wtf
Oct 10, 2025
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šŸ”„ Quick Take: The Big News in 60 Seconds

On September 30, 2025, the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) officially punted the

Start date for the new Residential Real Estate Reporting Rule to March 1, 2026 (originally December 1, 2025).

This means title and escrow companies have more time—but not forever—to prep for a sweeping new wave of anti-money laundering (AML) reporting requirements on certain residential, non-financed transactions.

Translation:

You’ve got an extension, but the work isn’t going away. And yes, the reporting form is live—so you can actually see what will be required, even if you don’t have to file yet.


Get Your Ready to Use Operations Guide & Forms Now!

šŸ‘€ What’s Actually Required—And Who’s on the Hook?

  • Who Reports: Title, escrow, and settlement companies (NOT just attorneys and NOT just lenders).

  • What Sort of Transactions Are Reported: Certain residential real estate transfers where no lender is involved (think: all-cash deals), in which the transferee is a legal entity or trust.

  • What’s Reported: including deep dives on buyers, sellers, and anyone with ā€œbeneficial ownership.ā€

  • How Many Files: Industry estimates say roughly 1 in 10 closings could be reportable.

  • What Form: The new FinCEN Real Estate Report (RER Form, OMB Control Number 1506-0080). It’s long, it’s nosy, and it’s not optional.

  • Third-Party Forms? Fine for internal info gathering, but ONLY the official FinCEN RER form can be filed.

  • Can I see the form? Yes, FinCEN has released a read only PDF with screenshots of the entire form and interface.

ā± Why the Delay?

FinCEN says the extension is to ā€œreduce business burden and ensure effective regulationā€ā€”translation: everyone (including underwriters, associations, and software vendors) told them implementation was a compliance nightmare at holiday-year end.

šŸ›‘ What’s NOT Changing

  • Geographic Targeting Orders (GTOs) stay in effect for now. If you’re in a GTO zone (think Miami, NYC, LA), you’re still reporting those deals.

  • This is a delay, not a repeal. AML reporting for real estate is coming—and no, you shouldn’t just ignore it until 2026. Preparing now by training staff and prepping your data collection workflows and forms will ease your transition and minimize the time involved in actually filing the report. I’ve even created an Easy Kit to make your training and prep time even faster!


Get your operations battle-ready: streamline, scale, succeed with BHConsulting

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šŸ‘€You’re Not Alone: Here’s Who Can Help You Tackle FinCEN Compliance (Without Losing Your Mind)

The new FinCEN reporting rule feels overwhelming—but you don’t have to go it alone or start from scratch. The industry’s best tech partners have been sprinting to make your life easier—and they’re rolling out practical, agent-friendly solutions right now.

Here’s who’s got your back (and what makes them worth a look):

šŸ”Closinglock

Compliance in Minutes—Not Weeks

Closinglock, the leader in secure digital payments and wire fraud prevention for real estate transactions, announced a new integrated solution that simplifies, centralizes, and automates data collection and storage required under the Financial Crime Enforcement Network (FinCEN) Anti-Money Laundering (AML) rule.

ā€œTitle companies are being asked to take on more compliance responsibility — and more risk — than ever before,ā€ said Andy White, Founder and CEO of Closinglock. ā€œWe know how much work title professionals put into each closing, and we hear their concerns about the impact of new regulations. By simplifying FinCEN data collection, we’re removing some of the burden title professionals would bear every day and replacing it with a process that ensures data is collected accurately, securely, and on time.ā€

This isn’t just lip-service in a press release, the features of this new service, like the features of their automated payoff retrieval service, demonstrate Closinglock’s deep understanding of the needs and concerns of title agencies.

  • No Added Cost: If you’re a Closinglock user, this is included—no nickel-and-diming.

  • Automated Data Collection: Send clients a secure, easy-to-use digital form that captures every required detail for FinCEN reporting.

  • Docusign Integration: Built-in certified e-signatures, tamper-proof records, and completion certificates—so you’ve got proof if anyone asks.

  • Compliance Data Retention: Every form is archived automatically for five years (per FinCEN’s rule), plus full audit trails (IP, ID, timestamps).

  • Seamless Integration: Forms and data sync right into your title production software, so you never lose track.

  • Reminders & Sync: Clients get auto-reminders, your team gets real-time alerts when forms are done, and everything syncs with your TPS.

FinCEN compliance isn’t just extra paperwork—it’s a potential 2–3 hour time sink for every reportable file. Closinglock is stepping up to turn a major compliance headache into a streamlined, set-it-and-forget-it workflow. That means more closings, fewer headaches, zero surprises.

If you use Closinglock, talk to your rep about turning this on. If you don’t—this is the time to ask for a demo.


Close with Confidence

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šŸ¦øā€ā™€ļø Wicked Title Forum’s FinCEN Toolkit

Built for Agents, by Agents—Ready-to-Use, No Fluff

Let’s be real: most ā€œcompliance guidesā€ are written by people who’ve never had to track down a missing payoff or calm a frantic closer at 4:59pm. That’s why I built the Wicked Title Forum FinCEN Reporting Toolkit—a plug-and-play resource created from the ground up for small agency teams and real working title pros.

What’s inside:

  • Instant-Use Templates: Attorney-reviewed client disclosure, email scripts, and internal cheat sheets to train your team in under 15 minutes.

  • Workflow Checklists: Step-by-step, idiot-proof—so you don’t miss a beat (or a required field).

  • Plain-English Explainers: No legalese, just real-world answers you can copy-paste into your client emails, agent updates, or policy memos.

  • Updates Included: Buy once and you’ll get every update, revision, or new form we add as the law evolves.

Why use it?

Because you want practical, field-tested tools—not another 40-page PDF from a vendor who’s never closed a deal.

Because you need to keep your team moving (and your blood pressure down).

Because this is what your competition wishes they had.

Grab the toolkit now—and get back to doing what you do best: closing deals, not chasing compliance nightmares.


Explore the Technology Solutions Available to Make Your Life Easier

Manual data wrangling will eat you alive. Leading vendors, like Closinglock, FinCEN Real Estate Report.com, Qualia, SoftPro, CloseSimple & Stewart are rolling out tools to automate FinCEN info gathering, secure e-sign, audit trails, and integrations with title production software.

šŸ”“Want more information on these tech solutions? Members keep scrolling or Join the Wicked Title Forum today!


šŸ›‘ What Happens If You Wait?

  • FOMO is real: Early adopters will iron out bugs, get their teams trained, and build a reputation for compliance (and avoid last-minute chaos).

  • Cost of Inaction: Wait too long, and you’ll be scrambling—with a greater risk of fines, reporting errors, and unhappy clients/partners. Your most efficient competitors will eat your lunch.


šŸ—£ļø Quick Scripts: What to Say to Your Team/Partners

  • To Your Team:
    ā€œThe deadline got pushed, but we’re not letting up. We’re getting ready now so March 2026 is a nonevent—not a disaster.ā€

  • To Agents/Clients:
    ā€œThere’s a new federal rule coming that will require more info for some cash deals. We’re ahead of the curve, so you’ll never be caught off guard.ā€


More Resources from FinCEN:

Orders, Rules & Announcements:

  • FinCEN Exemptive Relief Order to Delay the Effective Date of the Residential Real Estate Rule (Sept 30, 2025)

  • Real Estate Report Form Preview

  • Anti-Money Laundering Regulations for Residential Real Estate Transfers

Prepare

  • What is the Real Estate Report?

  • When is a transfer reportable?

  • Am I a reporting person?

  • Real Estate Fact Sheet

  • Residential Real Estate Frequently Asked Questions

File

  • File a report using the BSA E-Filing System

  • Create a BSA E-Filing account

  • Create a Login.gov account


More Resources from the Wicked Title Forum

  • 🐐🧾FinCEN AML RER: Comprehensive Guide for Title Agents

  • šŸšŸŽ™ļøUnderstanding the New FinCEN Real Estate Reporting Rule | Key Points for Title Insurance Agents

  • Easy Kit: FinCEN Real Estate Reporting: Operations Manual, Forms, Affidavits & Training Materials

  • šŸšŸ§¾šŸŽ™ļø FinCEN Listened (Sort Of): Updates that Title Agents Need to Know About the New Real Estate Report (RER) Rule

  • 🐐🧾You Asked, We Answered: ā€˜3 Hours Per Report?!’ and Other FinCEN Fears—Debunked


🚦 What’s Next? Don’t Just Wait—Get Wicked Practical.

Now you know the what, the who, and the why behind FinCEN’s latest compliance curveball. But knowing isn’t the same as doing—and let’s be honest, nobody’s career ever took off because they just read the headlines and hoped for the best.

Here’s your moment of choice:

  • Do you want to just ā€œwait and see,ā€ or do you want a clear, wicked-smart action plan that makes you the compliance hero in your office (without losing your mind)?

  • Are you ready to finally ditch the scramble and get ahead—so you’re leading the conversation instead of catching up in crisis mode?

šŸ”“Members Keep scrolling or join the Wicked Title Forum now to unlock the member-only playbook with:

  • šŸ’” Simple Step-by-step Practical Actions for Agencies To Do Right Now (yes, in plain English)

  • šŸ› ļø Deep-dive reviews of ALL the vendor solutions—FinCEN Real Estate Report, Qualia, SoftPro, and more

Because the title agents who prepare now are the ones who close faster, sleep better, and never have to scramble—or apologize—when new rules hit.

Ready for the ā€œhow-toā€ instead of just ā€œwhat now?ā€

šŸ‘‰ Members, scroll down for your next steps.

Not a member yet? Join Wicked Title Forum and never get blindsided by compliance again.


Stay Wicked,
Cheryl

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