ššØ The FinCEN Rule Delayed! What Changed, Why It Matters, and How to Actually Get Ready
FinCEN Postpones AML RuleāHereās What That Means for Your Workflow (And Sanity) Plus Some New Resources to Make This SO Much Easier!
š Explore All Things Wicked | š Subscribe | š¢ Be a Sponsor
š Explore All Things Wicked | š Subscribe | š¢ Be a Sponsor
š„ Quick Take: The Big News in 60 Seconds
On September 30, 2025, the U.S. Treasuryās 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 timeābut not foreverāto prep for a sweeping new wave of anti-money laundering (AML) reporting requirements on certain residential, non-financed transactions.
Translation:
Youāve got an extension, but the work isnāt going away. And yes, the reporting form is liveāso you can actually see what will be required, even if you donāt have to file yet.
š Whatās Actually RequiredāAnd Whoās 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.
Whatās Reported: including deep dives on buyers, sellers, and anyone with ābeneficial 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). Itās long, itās nosy, and itās 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 āreduce business burden and ensure effective regulationāātranslation: everyone (including underwriters, associations, and software vendors) told them implementation was a compliance nightmare at holiday-year end.
š Whatās NOT Changing
Geographic Targeting Orders (GTOs) stay in effect for now. If youāre in a GTO zone (think Miami, NYC, LA), youāre still reporting those deals.
This is a delay, not a repeal. AML reporting for real estate is comingāand no, you shouldnāt 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. Iāve even created an Easy Kit to make your training and prep time even faster!
š¢ Be a Sponsor | šPaid Subscribers Get Limited Time Free Downloads Here
šYouāre Not Alone: Hereās Who Can Help You Tackle FinCEN Compliance (Without Losing Your Mind)
The new FinCEN reporting rule feels overwhelmingābut you donāt have to go it alone or start from scratch. The industryās best tech partners have been sprinting to make your life easierāand theyāre rolling out practical, agent-friendly solutions right now.
Hereās whoās got your back (and what makes them worth a look):
šClosinglock
Compliance in MinutesāNot 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.
āTitle companies are being asked to take on more compliance responsibility ā and more risk ā than ever before,ā said Andy White, Founder and CEO of Closinglock. āWe 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, weāre 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 isnāt just lip-service in a press release, the features of this new service, like the features of their automated payoff retrieval service, demonstrate Closinglockās deep understanding of the needs and concerns of title agencies.
No Added Cost: If youāre a Closinglock user, this is includedāno 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 certificatesāso youāve got proof if anyone asks.
Compliance Data Retention: Every form is archived automatically for five years (per FinCENās 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 isnāt just extra paperworkāitās a potential 2ā3 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 donātāthis is the time to ask for a demo.
š¢ Be a Sponsor | šPaid Subscribers Get Limited Time Free Downloads Here
š¦øāāļø Wicked Title Forumās FinCEN Toolkit
Built for Agents, by AgentsāReady-to-Use, No Fluff
Letās be real: most ācompliance guidesā are written by people whoāve never had to track down a missing payoff or calm a frantic closer at 4:59pm. Thatās why I built the Wicked Title Forum FinCEN Reporting Toolkitāa plug-and-play resource created from the ground up for small agency teams and real working title pros.
Whatās 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-proofāso you donāt 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 youāll get every update, revision, or new form we add as the law evolves.
Why use it?
Because you want practical, field-tested toolsānot another 40-page PDF from a vendor whoās 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 nowāand 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.
šWant more information on these tech solutions? Members keep scrolling or Join the Wicked Title Forum today!
š 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 youāll be scramblingāwith a greater risk of fines, reporting errors, and unhappy clients/partners. Your most efficient competitors will eat your lunch.
š£ļø Quick Scripts: What to Say to Your Team/Partners
To Your Team:
āThe deadline got pushed, but weāre not letting up. Weāre getting ready now so March 2026 is a noneventānot a disaster.āTo Agents/Clients:
āThereās a new federal rule coming that will require more info for some cash deals. Weāre ahead of the curve, so youāll 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)
Anti-Money Laundering Regulations for Residential Real Estate Transfers
Prepare
File
More Resources from the Wicked Title Forum
šš§¾FinCEN AML RER: Comprehensive Guide for Title Agents
ššļøUnderstanding 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
šš§¾šļø FinCEN Listened (Sort Of): Updates that Title Agents Need to Know About the New Real Estate Report (RER) Rule
šš§¾You Asked, We Answered: ā3 Hours Per Report?!ā and Other FinCEN FearsāDebunked
š¦ Whatās Next? Donāt Just WaitāGet Wicked Practical.
Now you know the what, the who, and the why behind FinCENās latest compliance curveball. But knowing isnāt the same as doingāand letās be honest, nobodyās career ever took off because they just read the headlines and hoped for the best.
Hereās your moment of choice:
Do you want to just āwait 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 aheadāso youāre leading the conversation instead of catching up in crisis mode?
šMembers Keep scrolling or join the Wicked Title Forum now to unlock the member-only playbook with:
š” Simple Step-by-step Practical Actions for Agencies To Do Right Now (yes, in plain English)
š ļø Deep-dive reviews of ALL the vendor solutionsāFinCEN 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 scrambleāor apologizeāwhen new rules hit.
Ready for the āhow-toā instead of just āwhat now?ā
š 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
If you enjoy my writing, please support me with a clap, comment, follow, or subscribe.
š Explore All Things Wicked | š Subscribe | š¢ Be a Sponsor
**DISCLAIMER**
The Wicked Title Forum is a collaborative resource. If you spot something outdated or inaccurate, leave a commentāweāll get it fixed.
All sample forms, procedures, and instructional content are for general educational purposes only. They are not legal, financial, or underwriting advice, and should not be relied upon without first consulting with your attorney, underwriter, or compliance officer. Use of this material is at your own risk.
Some links may be affiliate or sponsor links. That means I might earn a commissionāat no extra cost to youāif you click. I only recommend things I use, trust, or have personally reviewed.
Keep reading with a 7-day free trial
Subscribe to Wicked Title Forum to keep reading this post and get 7 days of free access to the full post archives.









