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FinCEN Proposed Rule: Residential Real Estate Beneficial Ownership Reporting Requirements; Preparing for Compliance

Nationwide Scope; Covered Entities; Reportable Transferees; Reportable Transfers of Property; Exemptions

Recording of a 90-minute premium CLE video webinar with Q&A

This program is included with the Strafford CLE Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Conducted on Thursday, May 16, 2024

Recorded event now available

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This CLE webinar will guide practitioners through the Department of the Treasury's Financial Crimes Enforcement Network's (FinCEN) proposed rule to increase transparency in residential real estate transactions that will significantly impact covered real estate entities with extensive new reporting obligations. The panel will address who is covered by the proposed rule, the reporting requirements, and best practices to prepare for compliance.


In its ongoing efforts to combat and deter money laundering, FinCEN recently proposed a rule that would extend anti-money laundering reporting requirements to the residential real estate sector nationwide and increase transparency of certain non-financed real estate transactions.

The proposed rule would require covered businesses, including attorneys, performing specified closing or settlement functions for the non-financed sale or transfer of residential real property to an entity or trust to collect and report certain information to FinCEN in a Real Estate Report.

Reportable information includes beneficial ownership information for the legal entity (transferee entity) or trust (transferee trust) receiving the property, information about individuals representing the transferee entity or transferee trust, information about the business filing the report, information about the residential real property being sold or transferred, information about the transferor/seller, and information about any payments made.

Real estate counsel and clients should understand the extensive reporting requirements, including required reporting persons and reportable transfers of property and reportable transferees, in order to perform the due diligence required and put processes in place to prepare for reporting obligations.

Listen as our expert panel guides practitioners through the FinCEN proposed rule and discusses the impact the reporting requirements will have on covered real estate businesses. The panel will address interaction the new rule may have with the Corporate Transparency Act and offer best practices for taking steps now to prepare for compliance.



  1. Introduction to the proposed rule
    1. Purpose
    2. Bank Secrecy Act
    3. Residential Real Estate GTO Program
  2. Reporting requirements
    1. Reportable transfers of residential real property
    2. Reportable transferees
    3. Reportable information
    4. Reporting persons
    5. Filing reports and keeping records
    6. Exemptions
  3. Interaction with the Corporate Transparency Act
  4. Status of the proposed rule
  5. Preparing for compliance obligations


The panel will review these and other key considerations:

  • Who are required reporting entities?
  • What information will be required to be reported?
  • Who are the reportable transferees and to what residential real estate transactions does the proposed rule apply?
  • What interaction does the proposed rule have with the Corporate Transparency Act?
  • What steps should counsel and their clients take now to prepare for compliance?


Halpern, Jonathan
Jonathan N. Halpern

Partner, White Collar Defense and Investigations
Holland & Knight

Mr. Halpern represents corporations and individuals in investigations and prosecutions spanning a breadth of criminal...  |  Read More

LaViña, Salvador
Salvador P. LaViña

Partner, Real Estate Department Chair
Barnes & Thornburg

Mr. LaViña is Barnes & Thornburg’s Real Estate department chair. As a trusted business lawyer and...  |  Read More

Olman-Pal , Marina
Marina Olman-Pal

Shareholder, Co-Chair of Financial, Regulatory & Compliance Practice
Greenberg Traurig

Ms. Olman-Pal advises foreign and U.S. financial institutions on a broad range of regulatory matters including...  |  Read More

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