FinCEN Questions: What are the main reporting requirements for title and escrow companies under FinCEN?

The new FinCEN Residential Real Estate (RRE) Rule marks one of the most significant regulatory shifts in the history of the title industry. To remain compliant, it is essential to understand the main reporting requirements for title and escrow companies under FinCEN.

Starting March 1, 2026, certain professionals involved in real estate closings must file a "Real Estate Report" for specific non-financed transfers. This primarily applies to cash deals where the buyer is a legal entity or a trust. The reporting person is determined by a "reporting cascade," which typically places the responsibility on the settlement agent listed on the closing statement.

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The report itself is extensive, containing up to 111 possible data fields. Key requirements include collecting the full legal name, date of birth, residential address, citizenship, and taxpayer identification number (TIN) for every beneficial owner of the transferee entity or trust. Additionally, you must report property details, the total purchase price, and how the funds were paid. Reports are generally due by the last day of the month following the month of closing. Because sensitive data is involved, FinCEN expects these records to be stored securely for at least five years.

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