Change is Coming:

• FinCEN RRE hub
• Final rule (Federal Register)
• FAQs
• Fact sheet (PDF)
• BSA E-Filing (file RERs)
• BSA E-Filing overview

• What’s covered: Non-financed (including all-cash or financed by a lender without AML/SAR obligations) transfers to entities or trusts. Direct transfers to individuals are NOT covered.
• Where/threshold: Nationwide. No minimum price.
• Due date: File by the later of (a) the last day of the month after the closing month, or (b) 30 calendar days after closing.
• AML program: Not required for reporting persons under this rule.
• Privacy: Reports are not public; FinCEN stores them in the BSA system.
• Filing method: FinCEN’s BSA E-Filing (online HTML form, fillable PDF, or batch/SFTP once enabled).

A transfer that does NOT involve an extension of credit to all transferees that is both (1) secured by the property and (2) extended by a financial institution with AML program and SAR obligations.

If credit is extended by a lender without those obligations, the transfer is treated as non-financed and may be reportable.

• One-to-four family homes, townhouses, condos, co-ops (including individual units in larger buildings).
• Mixed-use that includes residential use.
• Certain land where the transferee intends to build a one-to-four family residence.

Exactly one person files the RER. If there’s no written designation agreement for that transfer, responsibility flows in this order:

1. Person listed as the closing/settlement agent on the closing/settlement statement
2. Preparer of the closing/settlement statement
3. Recorder of the transfer instrument(s)
4. Underwriter of the owner’s title insurance policy for the transferee
5. Greatest disburser of funds
6. Title status evaluator
7. Preparer of the deed (or transfer instrument; for co-ops, the stock certificate)
8. Designation agreements: Any two eligible parties may designate who files for a specific transfer. Each party must keep a copy for 5 years.

• Reporting person (name, cascade role, U.S. business address)
• Transferee entity or transferee trust
• Beneficial owners of that entity/trust (name, date of birth, residential address, citizenship, TIN)
• Individuals signing for the entity/trust
• Transferor information and property details (address/legal description; closing date)
• Total consideration and payment details (including payor if not the transferee)

Subject to FinCEN’s final RER form and technical specifications, AccuTitle is building features to help you:

• Identify likely reportable transactions
• Collect transferee/beneficial-owner data and capture signed certifications
• Track “later of end-of-month or 30-day” due dates
• Organize/retain evidence (designation agreements, certifications) for 5 years
• Support direct filing workflows once methods are finalized in BSA E-Filing
• We’ll publish release details and timelines after FinCEN finalizes materials.

• You may rely on others’ information absent red flags.
• For beneficial ownership, you may rely only on information certified in writing by the transferee or its representative.
• Keep the BOI certification and any designation agreement for 5 years. (You do not need to retain a copy of the RER itself.)

File via FinCEN’s BSA E-Filing: https://bsaefiling.fincen.treas.gov/

• Account setup: Your organization enrolls in BSA E-Filing; users authenticate with Login.gov.
• Filing options (as described by Treasury/FinCEN): online HTML form; PDF form; batch uploads on the site; or automated SFTP for bulk filings.

Filing directly through BSA E-Filing is free. Third-party providers may charge fees—review their terms carefully.

File by the last day of the month after the closing month OR 30 calendar days after closing—whichever is later.

Example: Closing on March 10 → due April 30 (later than April 9).

• Civil penalties:
  • Negligent violation: up to $1,430 per violation
  • Pattern of negligent activity: up to $111,308
  • General willful civil penalty: approx. $71,545–$286,184 (range depends on statute)
• Criminal penalties for willful violations can include up to 5 years’ imprisonment and fines, or up to 10 years/$500,000 if part of a qualifying pattern or with another U.S. law violation.

Industry challenges are pending (e.g., Flowers Title Companies, LLC v. Bessent in E.D. Tex.; Fidelity National Financial, Inc. v. Bessent in M.D. Fla.).

As of today, FinCEN’s official hub still lists December 1, 2025 as the effective date.

This resource consolidates official FinCEN materials for title professionals. It is for information only and not legal advice. AccuTitle is a software provider and does not provide legal services.

Last updated: September 11, 2025