11/03/2025
Here’s What’s Changing — and Why It Matters
The Financial Crimes Enforcement Network (FinCEN) now requires certain real estate transactions to report beneficial ownership information. The goal? To stop illegal funds from being hidden in real estate.
This affects:
🏢 Entity Buyers – LLCs, corporations, partnerships, or trusts
💵 Non-Financed Purchases – no traditional FDIC-insured loan or mortgage
🏠 Residential & Mobile Home Sales – both are covered - as well as vacant land if the buyer intends to develop it into a single family residence!!!!
If your deal fits these categories, you’ll be required to complete new disclosure forms before closing.
🧾 The Forms You’ll See (And What They Mean)
1️⃣ FRR-PA – Financial Reporting Requirement
This is the CAR that is included in many RPA agreements - where both buyer and seller agree to provide the required FinCEN data.
2️⃣ RER Form 508C – Real Estate Reporting form
This form collects a minimum of 111 data points (yes, 111+). It identifies who’s behind an entity, who controls funds, and who ultimately benefits from the purchase.
3️⃣ RFF Form – Request for FinCEN Filing
This will be your “data-submission packet.” It’s how you officially provide ownership information, ID verification, and funding sources.
💡 We’ll make it easy & included in your escrow fees! That's right, its INCLUDED, no extra junk fees just the service you've come to expect from us!
Data Collection Starts: December 1, 2024
Official FinCEN Reporting Begins: March 1, 2025
Deadline to Submit: Within 7 days of our request
Failing to provide the required information within that timeframe could result in a breach of contract under the FRR-PA — and may delay or jeopardize your closing.
🤝 For Agents
This update is a must-share for your buyers and sellers. Here’s why:
1. Your entity or trust clients will need to plan ahead for ID and ownership documentation.
2. Your cash buyers may have to provide source-of-funds verification even when no lender is involved.
3. Your listing side may need to verify that buyers understand their FinCEN obligations before acceptance.
A quick heads-up now can prevent delays later — and protect you from compliance headaches.
Our Escrow Office Is Ready
We’ll start collecting required FinCEN data beginning December 1st for any file closing March 1st or later.
✅ No extra software
✅ Simple upload process
✅ Support for agents, buyers, and sellers every step of the way
Bottom Line
If you’re paying cash, buying in a trust, or taking title in an LLC — this applies to you.
If you’re an agent working with these types of clients — this protects you too.
👉 Read this. Save it. Share it.
This is the update everyone in real estate will be talking about by March.
We’ll keep you ahead of it. That’s what Menifee Valley Escrow & Keys to the Contract is all about.
