02/11/2026
NEW FinCEN REAL ESTATE REPORTING REQUIREMENTS – EFFECTIVE MARCH 1
If you buy, sell, invest, or use LLCs/trusts in real estate… this impacts you.
Here’s what you need to know:
1. All 1–4 Unit Residential Transfers Are Reviewed
Closings March 1 or later fall under new federal anti-money-laundering reporting rules — regardless of deed type.
2. Buying with an LLC, Trust, Corporation, or Partnership?
Full disclosure is required:
• Anyone with 25%+ ownership
• Indirect ownership chains
• For trusts: trust date, trustee, successor trustee, beneficiaries
3. Cash Deals Are Reportable
Cash, land contracts, and non-financed transactions are reportable unless specifically exempt.
4. Title Companies Must File
If the lender does not report under AML, the title company must.
5. Digital Questionnaire Before Closing
Buyers & sellers will complete a detailed electronic questionnaire (111 questions).
All answers must be e-signed.
Incomplete info can delay closing.
6. Non-Compliance Is Serious
• Up to $250,000 fines
• Up to 5 years in prison
• Federal AML violations
7. Some Transfers May Be Exempt
Certain probate transfers, properly structured 1031 exchanges, and court-supervised sales may qualify but assume reportable until verified.
8. Funding Sources Must Match
Earnest money + closing funds must align with verified bank sources.
If you’re investing in Detroit or Southeast Michigan using an entity, let’s structure it correctly from the beginning.
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DM me “FINCEN” for a simple compliance prep checklist before you write your next offer.