Name: FinCEN Nationwide Residential Real Estate Reporting Rule - Blocked by Federal Court
Creator: Soflo Consulting
Published: 2024-08-29
License: https://www.usa.gov/government-works

Question 1

Is there a FinCEN Geographic Targeting Order (GTO) in All 50 States, District of Columbia, U.S. Territories?

Accepted Answer

There was previously a FinCEN GTO covering Nationwide - all U.S. jurisdictions. The order is currently superseded. FinCEN's permanent nationwide residential real estate reporting rule took effect March 1, 2026, replacing all Geographic Targeting Orders (GTOs). It was vacated on March 19, 2026 by the U.S. District Court for the Eastern District of Texas in Flowers Title Companies v. Bessent, and FinCEN and DOJ appealed that decision in May 2026. Reporting is therefore not currently required: reporting persons are not required to file real estate reports with FinCEN and are not subject to liability if they fail to do so while the vacatur remains in force. All prior residential real estate GTOs remain superseded.

Question 2

What is the reporting threshold for the All 50 States, District of Columbia, U.S. Territories GTO?

Accepted Answer

The reporting threshold for this GTO is $0. Settlement agents, title insurance agents, escrow agents, attorneys, and other real estate professionals involved in non-financed residential transfers must report beneficial ownership information for legal entities purchasing residential real property for $0 or more in all-cash transactions within the covered jurisdiction.

Question 3

Who must comply with the FinCEN GTO in All 50 States, District of Columbia, U.S. Territories?

Accepted Answer

Settlement agents, title insurance agents, escrow agents, attorneys, and other real estate professionals involved in non-financed residential transfers operating in Nationwide - all U.S. jurisdictions must comply with this GTO. Specifically, they must: BLOCKED by federal court order. Reporting persons are not currently required to file real estate reports with FinCEN while the order remains in force..

Question 4

When did the All 50 States, District of Columbia, U.S. Territories FinCEN GTO take effect?

Accepted Answer

This GTO became effective on 2026-03-01. No expiration date has been published, indicating the order is ongoing pending FinCEN's permanent beneficial ownership rule for real estate.

Question 5

Where can I find the official FinCEN order for All 50 States, District of Columbia, U.S. Territories?

Accepted Answer

The official source for this GTO is available at https://www.fincen.gov/rre. The order PDF can be downloaded directly from https://www.govinfo.gov/content/pkg/FR-2024-08-29/pdf/2024-19198.pdf. Always verify current GTO status directly with FinCEN before making compliance decisions.

FinCEN Nationwide Residential Real Estate Reporting Rule - Blocked by Federal Court

Order Summary

Geographic Coverage

Reporting Requirements

Change Log

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