A Transaction Coordinator’s Perspective from Capital City Coordination

If you’ve been in real estate for any length of time, you may already be familiar with Geographic Targeting Orders (GTOs). These temporary reporting requirements, issued by the U.S. Treasury Department and managed by the Financial Crimes Enforcement Network (FinCEN), required additional reporting for certain cash purchases in specific markets.

For many agents, GTOs felt localized. Limited. Market-specific.

That’s about to change.

Beginning March 1, 2026, a new federal requirement known as the FinCEN Residential Real Estate Rule will significantly expand reporting requirements nationwide. Title companies across the country will be required to report certain qualifying residential real estate transactions to the U.S. Treasury.

This is not temporary.
This is not county-specific.
And it will impact transactions in every state.

As your transaction coordination partner at Capital City Coordination, our role is to help you stay informed and prepared, not reactive. Let’s walk through what this rule is, when it applies, and how you can prepare your business now.

What Is the FinCEN Residential Real Estate Rule?

The FinCEN real estate report is a new federal anti–money laundering report filed with the U.S. Treasury (FinCEN) for certain residential real estate transfers starting in 2026

It is:

Not public record
Filed by a closing professional (typically title or settlement)
Required when a transaction meets certain criteria

The rule is designed to:

Prevent money laundering
Protect the housing market
Identify the real individuals behind entities and trusts

Historically, GTOs targeted specific counties and price thresholds. The new Residential Real Estate Rule broadens the scope to apply nationwide under defined transaction conditions.

When Is a FinCEN Report Required?

A report is generally required when a transaction meets all of the following conditions:

The property is residential real estate
The buyer is an entity (LLC, corporation, partnership) or trust
There is no traditional bank mortgage involved (cash, private money, hard money, or seller financing often trigger reporting)
It applies in all states
It may include no-cost transfers such as gifts
Some transfers are exempt, and escrow can confirm applicability

The key trigger agents should watch for:
Entity or trust buyer + no traditional institutional lender.

You do not file this report. The title company does

However, agents play a critical role in preparing clients for what’s coming.

What Information Will Be Required?

Depending on the transaction, buyers and sellers may be asked to provide:

Legal names and addresses
Dates of birth
Identification numbers (SSN, ITIN, passport, etc.)
Information about who controls or owns an entity or trust
Source of funds used for the purchase

All information must be certified as accurate

.For Entity Buyers (LLCs, Corporations, Partnerships)

Title may request:

Entity legal name, address, jurisdiction, EIN
Individuals with 25% or greater ownership
Individuals with substantial decision-making authority
Identification of the real individuals behind any parent entities

For Trust Buyers

Title may request:

Trust name
Date executed
Whether revocable or irrevocable
Trustees
Grantors with withdrawal rights
Beneficiaries with substantial withdrawal authority

For Individuals Associated with the Entity

For each listed individual:

Legal name
Date of birth
Home address
Taxpayer ID
Government-issued ID image
How funds are paid (wire, check, etc.)
Source account information (bank name and account number)

Sellers may also be asked for identifying information and taxpayer ID

If required information is not provided, the title company cannot complete the closing. Delays or cancellation may occur

Why This Matters for Realtors®

From a transaction coordination standpoint, deals rarely fall apart because of the obvious items.

They fall apart because of surprises.

When a buyer who has purchased multiple properties in an LLC suddenly learns, days before closing, that they must provide:

Ownership structure details
SSN or ITIN
Government ID
Source-of-funds documentation

It can create frustration, distrust, and delay.

Your role isn’t to file federal reports.
Your role is to prepare your client so nothing feels unexpected.

How Agents Can Prepare Now

1. Identify Entity Buyers Early

During buyer consultation, ask:

Will you be purchasing in your personal name or an entity?
Is a traditional bank mortgage involved?
Is there a trust structure?

Early awareness prevents last-minute scrambling.

2. Set Expectations in Initial Conversations

Normalize it.

Instead of presenting it as a last-minute request from title, explain:

“Beginning in 2026, federal regulations require additional reporting for certain entity and trust purchases. Title will collect ownership and identification information before closing.”

Clients are far more cooperative when they understand this is a federal requirement—not a preference

.3. Educate Your Investor Clients Now

If you regularly work with:

LLC buyers
Private or hard money investors
Trust purchasers
Family gift transfers

Start the conversation before March 2026.

Sophisticated investors appreciate proactive communication.

4. Update Your Buyer Intake Process

Consider adding questions about:

Entity ownership structure
Percentage ownership
Whether another entity owns part of the entity
Trust involvement
Lending structure

You’re not collecting documentation, you’re creating awareness.

5. Prepare Clients for Source-of-Funds Transparency

Buyers may need to disclose how funds are paid and source account information

Encourage them to:

Confirm entity documents are current
Coordinate with their CPA or attorney
Prepare ownership documentation in advance

6. Partner Closely with Your Title Company

The title or settlement company is responsible for determining applicability and filing the report

They will:

Send a secure link to complete the required form
Collect necessary information
Submit the report through the appropriate government system

Ask your title partners now:

How early will they notify parties?
How much lead time will they require?
What exemptions apply?

Preparation strengthens relationships and prevents delays.

7. Build Time Cushion Into Your Transactions

Simple structures may take only minutes to complete. Complex entities or trusts may take longer

Plan accordingly in:

Option periods
Closing timelines
Competitive offer strategies

Especially when dealing with layered ownership structures.

8. Prepare Sellers Too

Sellers may be asked for identifying information and taxpayer ID

Explain that:

Federal reporting may apply
They may receive a secure form
Prompt response prevents delays

Prepared sellers are cooperative sellers.

9. Understand That Non-Compliance Stops the Closing

If required information is not provided:

The title company cannot close
Delays or cancellation may occur

In today’s competitive markets, that matters.

10. Work in Partnership with Title and Let Coordination Support the Process

When it comes to the FinCEN Residential Real Estate Rule, responsibility for collecting required information and filing the report rests with the title or settlement company

Title will:

Determine whether the transaction triggers reporting
Send the secure form to the appropriate parties
Collect required ownership and identification information
Submit the report to FinCEN

At Capital City Coordination, we do not collect confidential documentation or file federal reports.

Our role is to support the process by:

Identifying early when a transaction may involve an entity or trust
Looping in title proactively
Communicating timelines clearly to agents
Coordinating between title and clients when questions arise
Helping keep the closing calendar on track

When title, agent, client, and coordinator are aligned early, the result is what everyone wants:
A smooth, on-time closing, even in a more regulated environment.

Final Thoughts

The FinCEN Residential Real Estate Rule marks a significant shift in compliance requirements for residential transactions nationwide.

March 1, 2026 is closer than it feels.

Agents who prepare now will:

Experience fewer surprises
Protect their timelines
Strengthen client trust
Position themselves as informed professionals

Compliance is becoming part of the competitive advantage.

At Capital City Coordination, we believe preparation prevents friction and informed agents close smoother transactions.

Disclaimer:

This blog post is provided for informational purposes only and is not intended as legal, tax, or regulatory advice. Regulations and interpretations may change, and applicability may vary by transaction. Real estate agents should verify all requirements with their broker, legal counsel, and title professionals to ensure compliance with current federal, state, and brokerage policies. Capital City Coordination does not provide legal advice and assumes no liability for actions taken based on this information.