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UPDATED NOTIFICATIONS
Below is an Underwriting Bulletin provided by one of our underwriters, Fidelity National Title, regarding recent developments as of March 24, 2026.
With the uncertainty of an appeal and/or outcome, LM Title recommends continuing to gather and report information pursuant to the FinCEN Residential Real Estate Transfers Rule.
FinCEN Residential
Real Estate Reporting Rule
After an earlier postponement, Financial Crimes Enforcement Network (FinCEN) Anti-Money Laundering (AML) reporting regulations remain scheduled to go into effect March 1, 2026.
What to Report?
Residential Real Estate
All Cash or Non-Institutional Lender
Transferring to an Entity or Trust
Doesn't meet exception or exemption
Transactions closing on or after March 1, 2026
(closing is date ownership interest is received)
Who must Report?
Typically, the closing attorney
(settlement agent to the transaction, cascade hierarchy structure, or agreement)
When to Report?
Last day of the month following closing
or 30 calendar days after closing
How to Report?
Electronically with FinCEN Real Estate Report form
Why?
To enhance transparency and deter illicit financial activities because all-cash transactions involving entities or trusts have been identified as high-risk for money laundering activities due to the potential for anonymity.
LM Title presented a special 2026 Update CLE on February 4th discussing FinCEN,
the new Forgery/Fraud ALTA 49/49.1 Endorsements, and clarifications of recent
changes to the equitable distribution and elective share statutes.
To view the recording and PowerPoint slides for this CLE, click here.
FinCEN information provided by our underwriters
*Please note First American and WFGs are national events and information provided may not be specific to North Carolina or how North Carolina real estate transactions are conducted.