FinCEN Resources
Where federal financial-crime reporting requirements currently stand for real estate transactions, and what they mean for your closing.
Current as of 19 August 2026
These requirements have changed significantly in 2025 and 2026 and parts are still being litigated. This page reflects the position as of the date above. Always confirm current requirements with FinCEN or your legal counsel before relying on this information.
Beneficial Ownership Reporting (Corporate Transparency Act)
U.S. companies exemptThe Corporate Transparency Act originally required most companies formed in the United States to report their beneficial owners to the Financial Crimes Enforcement Network. That requirement no longer applies to domestic companies.
Under the final rule effective 14 August 2026, companies formed in the United States are exempt from beneficial ownership information reporting and are not required to file BOI reports. The requirement now applies only to entities formed under foreign law that have registered to do business in the United States, and those entities are not required to report beneficial owners who are U.S. persons.
What this means for your closing: if you are purchasing property through an Ohio LLC, or any other entity formed in the United States, you do not have a BOI filing obligation with FinCEN.
Authority: FinCEN Beneficial Ownership Information Reporting
Residential Real Estate Rule
Vacated - no filing required at presentFinCEN's Residential Real Estate Rule took effect on 1 March 2026. It made the settlement agent - usually the title company conducting the closing - the reporting person for non-financed transfers of residential property to legal entities or trusts. Unlike the framework it replaced, it applied nationwide with no dollar threshold.
On 19 March 2026 the United States District Court for the Eastern District of Texas vacated the rule nationwide, finding that FinCEN lacked the legal authority to issue it. FinCEN has appealed the decision, and the court's order remains in force while that appeal proceeds.
FinCEN has confirmed that reporting persons are not currently required to file Real Estate Reports and are not subject to liability if they do not file while the court's order remains in force. FinCEN has also confirmed that if the order is later overturned, reports will not be required retroactively for transactions that closed during the period the order was in force.
What this means for your closing: we are not collecting additional FinCEN beneficial ownership information for entity purchases at this time. If the rule is reinstated, we will tell you exactly what is needed and when.
Geographic Targeting Orders
SupersededGeographic Targeting Orders required title companies to report all-cash purchases of residential property by legal entities above set thresholds in specific metropolitan areas. That geographically limited framework was replaced by the nationwide Residential Real Estate Rule described above and is no longer the operative requirement.
Our Compliance Commitment
First Source Title monitors these requirements closely. Where reporting obligations apply to a transaction, we handle them and tell you clearly what information we need and why. Any information collected for compliance purposes is kept confidential and used only for the regulatory purpose for which it was gathered.
Questions About FinCEN Compliance?
Our team can explain what applies to your specific transaction. Reach out before closing and we will walk you through it.
This page is general information about federal reporting requirements and is not legal advice. Requirements change and are subject to ongoing litigation. Consult your attorney about your specific circumstances.