đđ¨ The FinCEN Rule Delayed! What Changed, Why It Matters, and How to Actually Get Ready
FinCEN Postpones AML RuleâHereâs What That Means for Your Workflow (And Sanity) Plus Some New Resources to Make This SO Much Easier!
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đĽ Quick Take: The Big News in 60 Seconds
On September 30, 2025, the U.S. Treasuryâs 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 timeâbut not foreverâto prep for a sweeping new wave of anti-money laundering (AML) reporting requirements on certain residential, non-financed transactions.
Translation:
Youâve got an extension, but the work isnât going away. And yes, the reporting form is liveâso you can actually see what will be required, even if you donât have to file yet.
đ Whatâs Actually RequiredâAnd Whoâs 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.
Whatâs Reported: including deep dives on buyers, sellers, and anyone with âbeneficial ownership.â
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). Itâs long, itâs nosy, and itâs 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.
âą Why the Delay?
FinCEN says the extension is to âreduce business burden and ensure effective regulationââtranslation: everyone (including underwriters, associations, and software vendors) told them implementation was a compliance nightmare at holiday-year end.
đ Whatâs NOT Changing
Geographic Targeting Orders (GTOs) stay in effect for now. If youâre in a GTO zone (think Miami, NYC, LA), youâre still reporting those deals.
This is a delay, not a repeal. AML reporting for real estate is comingâand no, you shouldnât 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. Iâve even created an Easy Kit to make your training and prep time even faster!
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đYouâre Not Alone: Hereâs Who Can Help You Tackle FinCEN Compliance (Without Losing Your Mind)
The new FinCEN reporting rule feels overwhelmingâbut you donât have to go it alone or start from scratch. The industryâs best tech partners have been sprinting to make your life easierâand theyâre rolling out practical, agent-friendly solutions right now.
Hereâs whoâs got your back (and what makes them worth a look):
đClosinglock
Compliance in MinutesâNot 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.
âTitle companies are being asked to take on more compliance responsibility â and more risk â than ever before,â said Andy White, Founder and CEO of Closinglock. âWe 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, weâre 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.â
This isnât just lip-service in a press release, the features of this new service, like the features of their automated payoff retrieval service, demonstrate Closinglockâs deep understanding of the needs and concerns of title agencies.
No Added Cost: If youâre a Closinglock user, this is includedâno 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 certificatesâso youâve got proof if anyone asks.
Compliance Data Retention: Every form is archived automatically for five years (per FinCENâs 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 isnât just extra paperworkâitâs a potential 2â3 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 donâtâthis is the time to ask for a demo.
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đڏââď¸ Wicked Title Forumâs FinCEN Toolkit
Built for Agents, by AgentsâReady-to-Use, No Fluff
Letâs be real: most âcompliance guidesâ are written by people whoâve never had to track down a missing payoff or calm a frantic closer at 4:59pm. Thatâs why I built the Wicked Title Forum FinCEN Reporting Toolkitâa plug-and-play resource created from the ground up for small agency teams and real working title pros.
Whatâs 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-proofâso you donât 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 youâll get every update, revision, or new form we add as the law evolves.
Why use it?
Because you want practical, field-tested toolsânot another 40-page PDF from a vendor whoâs 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 nowâand 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.
đWant more information on these tech solutions? Members keep scrolling or Join the Wicked Title Forum today!
đ 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 youâll be scramblingâwith a greater risk of fines, reporting errors, and unhappy clients/partners. Your most efficient competitors will eat your lunch.
đŁď¸ Quick Scripts: What to Say to Your Team/Partners
To Your Team:
âThe deadline got pushed, but weâre not letting up. Weâre getting ready now so March 2026 is a noneventânot a disaster.âTo Agents/Clients:
âThereâs a new federal rule coming that will require more info for some cash deals. Weâre ahead of the curve, so youâll never be caught off guard.â
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
đđ§žFinCEN AML RER: Comprehensive Guide for Title Agents
đđď¸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
đđ§žđď¸ FinCEN Listened (Sort Of): Updates that Title Agents Need to Know About the New Real Estate Report (RER) Rule
đđ§žYou Asked, We Answered: â3 Hours Per Report?!â and Other FinCEN FearsâDebunked
đŚ Whatâs Next? Donât Just WaitâGet Wicked Practical.
Now you know the what, the who, and the why behind FinCENâs latest compliance curveball. But knowing isnât the same as doingâand letâs be honest, nobodyâs career ever took off because they just read the headlines and hoped for the best.
Hereâs your moment of choice:
Do you want to just âwait and see,â 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 aheadâso youâre leading the conversation instead of catching up in crisis mode?
đMembers Keep scrolling or join the Wicked Title Forum now to unlock the member-only playbook with:
đĄ Simple Step-by-step Practical Actions for Agencies To Do Right Now (yes, in plain English)
đ ď¸ Deep-dive reviews of ALL the vendor solutionsâFinCEN 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 scrambleâor apologizeâwhen new rules hit.
Ready for the âhow-toâ instead of just âwhat now?â
đ 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.
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