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1. General Questions

1.1  What is the Residential Real Estate Report?

The Residential Real Estate Report is a new filing requirement from FinCEN that applies to certain real estate closings and settlements. It covers non-financed (often “all-cash”) transfers of residential property to legal entities or trusts, which are considered higher risk for money laundering.

The purpose of the report is to increase transparency in real estate transactions and help law enforcement combat illicit finance. While many people use trusts and companies legitimately, bad actors often hide behind them to disguise ownership.

Reports will be securely stored by FinCEN and will not be public. Only authorized law enforcement and government users can access the data.

1.2  When does the rule take effect?

The final rule goes into effect on March 1, 2026. 

2. Reportable Transfers

2.1  When must a Real Estate Report be filed?

A report is required whenever there is a non-financed transfer of residential real estate to a transferee entity (like a company) or a transferee trust.

2.2  What counts as residential real property?

The rule covers:

  • Single-family homes, townhouses, and condos
  • Cooperatives (co-ops)
  • Multi-unit buildings designed for 1–4 families
  • Land where a 1–4 family residence will be built
  • Co-op shares tied to U.S. residential property

Even if there’s a small commercial element (like an apartment over a shop), the property still qualifies. 

2.3  What is a transfer?

Any change of ownership—whether through a deed, stock/share certificate (in a co-op), or other legal document. This includes both purchases and gifts. 

2.4  What does “non-financed” mean?

A non-financed transfer does not involve a traditional mortgage or other loan from a financial institution that has AML/SAR obligations. “All-cash” deals are the most common example. 

2.5  Which transfers are not reportable?

Examples of exempt transfers include:

  • Easements
  • Transfers after death (inheritance, wills, etc.)
  • Divorce or dissolution-related transfers
  • Transfers to bankruptcy estates
  • Court-supervised transfers
  • Transfers by individuals into a trust they created for themselves/spouse
  • Like-kind (1031) exchanges
  • Situations with no “reporting person” 

2.6  What is a transferee entity?

Any non-individual (corporation, LLC, partnership, etc.). Some are exempt, such as banks, government agencies, insurance companies, and SEC-registered issuers.

2.7  What is a transferee trust?

A legal arrangement where a trustee holds property for beneficiaries. Most trusts qualify, but some (like statutory trusts or those tied to exempt entities) are exempt. 

2.8  Can there be multiple transferees?

Yes. Even if one is exempt, the transfer is still reportable if at least one is not exempt.

3. Reporting Persons

3.1  Who files the report?

The responsibility falls on the “reporting person,” determined either by:

  • The reporting cascade (a priority list of professionals), or
  • A designation agreement (a written agreement assigning responsibility). 

3.2  What is the reporting cascade?

It’s a step-down order of responsibility. The person who first fits one of these roles must file:

  1. Closing/settlement agent listed on the closing statement
  2. Preparer of the closing statement
  3. Person who files the deed
  4. Title insurance underwriter
  5. Person who disburses funds
  6. Title evaluator
  7. Preparer of the deed or other transfer instrument

If no one performs these roles, no report is required. 

3.3  What is a designation agreement?

Parties may agree in writing to assign filing responsibility to another professional in the cascade. Each transfer requires its own written agreement, which must be retained for five years.

3.4  Does the rule require an AML program?

No. Unlike banks, real estate professionals subject to this rule are not required to implement AML programs. 

4. Required Information 

4.1  What information must be reported?

Reports must identify:

  • The property and transfer details
  • The transferor and transferee (entity or trust)
  • Individuals representing the transferee
  • Beneficial owners of transferee entities/trusts
  • Payment and consideration details

Beneficial owners include those who:

  • Control the entity/trust
  • Own/control 25% or more of an entity
  • Are trustees, certain beneficiaries, or grantors of trusts 

4.2  How should the reporting person gather the required information?

The reporting person can rely on information from the transferee or their representative, if it is certified in writing as accurate to the best of their knowledge.

5. Reporting and Recordkeeping

5.1  When is the report due?

By the last day of the month after closing, or 30 days after closing—whichever is later. 

5.2  What records must be kept?

Reporting persons must keep:

  • Beneficial ownership certifications
  • Any designation agreements

These must be retained for five years, though the actual report itself does not need to be retained.

6. Platform Questions

6.1  What is RRE Report?

RRE Report is a secure, cloud-based platform that helps real estate professionals comply with FinCEN’s Residential Real Estate Rule. Our software simplifies reporting, tracks deadlines, and stores records in one easy-to-use dashboard.

6.2  Who can use RRE Report?

Our platform is designed for:

  • Real estate attorneys
  • Title agents and settlement companies
  • Law firms and compliance teams
  • Property managers handling entity transactions

If you’re involved in non-financed residential transfers, RRE Report makes compliance seamless. 

6.3  How do I get started?

Simply create an account or log in to your firm dashboard here https://www.rrereport.com. Once inside, you can:

  • Add team members with different roles/permissions
  • Input transfer details
  • Generate reports and track filing deadlines

We also provide step-by-step training videos and onboarding support. 

6.4  Is my data secure? 

Yes. We use bank-level encryption, secure cloud storage, and strict access controls. Only authorized users at your firm can access your data, and we never share it with third parties. 

6.5  How much does it cost?

We offer flexible pricing based on your firm’s size and transaction volume. Please contact sales or request a demo for a tailored quote at info@fincenreport.com.

6.6  Do you offer training or support?

Yes. We provide:

  • A full knowledge base with guides and tutorials
  • Live customer support by email or phone
  • Optional one-on-one training sessions for firms

Our customer success team ensures you’re never on your own.

6.7  Can multiple team members use the software?

Absolutely. You can add team members, assign permissions, and control access so the right people have the right tools. 

6.8  How long does setup take?

Most firms are up and running in less than an hour. Our onboarding process is designed to be quick, with guided steps and optional live support. 

6.9  Do you integrate with other systems?

Yes, we integrate with leading case management, title, and accounting systems. We also provide export options for your compliance and internal recordkeeping needs. 

6.10  What if I have more questions?

You can always reach us at [support@fincenreport.com]. Our team is happy to help.