FinCEN's New Residential Real Estate Reporting Rule: Covered Entities and Property Transfers; Reporting Requirements
Effective Dec. 1, 2025; Best Practices for Preparation and Compliance
A live 90-minute premium CLE video webinar with interactive Q&A
This CLE webinar will guide practitioners through the Department of the Treasury's Financial Crimes Enforcement Network's (FinCEN) long-awaited residential real estate reporting rule, effective Dec. 1, 2025, to increase transparency in non-financed residential real estate transactions that will significantly impact covered real estate entities. The panel will address who is covered by the new rule, the reporting requirements, and best practices to prepare for compliance.
Outline
- Introduction to the final rule
- Purpose
- Bank Secrecy Act
- Residential Real Estate GTO Program
- The final rule
- Covered transfers of residential real property
- Reporting requirements
- Reporting persons
- Report filing and recordkeeping
- Exemptions
- Penalties for noncompliance
- Compliance timeline
- Next steps: preparing for compliance obligations
- Practitioner takeaways
Benefits
The panel will review these and other important considerations:
- Who are required reporting entities? Reporting persons?
- What information will be required to be reported?
- Who are the reportable transferees and to what residential real estate transactions does the final rule apply?
- What steps should counsel and their clients take now to prepare for compliance?
Faculty

Kyle R. Freeny
Shareholder
Greenberg Traurig
Ms. Freeny, a skilled trial attorney and former federal prosecutor for the Special Counsel’s Office and the... | Read More
Ms. Freeny, a skilled trial attorney and former federal prosecutor for the Special Counsel’s Office and the Department of Justice’s Money Laundering and Asset Recovery Section, draws on more than a dozen years of high-profile experience in the federal government to help clients navigate sensitive government and internal investigations, criminal and civil enforcement matters, and related complex litigation. She has particular experience in matters involving complex financial crime, cross-border investigations, anti-money laundering, anti-corruption, economic sanctions, asset forfeiture, and affirmative challenges to federal agency action. Ms. Freeny counsels clients facing scrutiny from DOJ, the SEC, FinCEN, and other law enforcement and financial regulatory agencies. She conducts internal investigations on a range of issues and advises clients on a wide array of anti-money laundering, anti-corruption, and other compliance issues.
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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
Mr. Halpern represents corporations and individuals in investigations and prosecutions spanning a breadth of criminal issues. He has litigated complex criminal and civil matters, but a substantial portion of his defense practice entails engaging with prosecutors and regulatory lawyers to resolve federal and state criminal and agency investigations for his clients away from the public spotlight. Mr. Halpern represents corporate and individual clients in internal and government investigations in a wide array of criminal, cross-border and compliance issues. Business and educational institutions and individuals turn to Mr. Halpern to represent them in a broad array of matters encompassing financial services; cybersecurity; Foreign Corrupt Practices Act; false claims and other healthcare matters; securities, commodities, and tax, among other issues. He represents clients in federal and state court, as well as in matters involving U.S. Attorney's Offices, New York State Attorney General's Office, New York County District Attorney's Office, U.S. Department of Justice, U.S. Department of the Treasury, SEC, and Commodity Futures Trading Commission. Mr. Halpern is a seasoned litigator who draws on his extensive experience in a wide array of white collar criminal defense matters and as a former federal prosecutor in the Southern District of New York.
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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
Mr. LaViña is Barnes & Thornburg’s Real Estate department chair. As a trusted business lawyer and adviser, he closes complex transactions and provides strategic advice to his many successful clients. With more than three decades of experience, Mr. LaViña serves as a battle-tested leader who listens attentively and executes client objectives swiftly, whether closing a multistate marquee deal or fixing a local problem. Clients turn to him for guidance with their deal ventures and he has closed or supervised transactions totaling nearly $15 billion dollars over the past decade. Mr. LaViña is a skilled negotiator and communicator with deep experience in virtually all areas of real estate, including acquisitions and sales, joint ventures, multifamily transactions, 1031 exchanges, real estate fund formation, development and construction, public-private and multistate matters, and he is even a licensed broker that works on his own deals. Mr. LaViña also represents developers, builders, brokers, sellers and buyers of high-end residential properties in California, including family offices, high net worth individuals, celebrities, athletes, and others. He is an invited guest speaker throughout the business community on real estate, finance, forecasting and business development topics.
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