Note from our Continuing Education Task Force Chair:  

I recently attended a broker class by Brad on FinCEN’s upcoming nationwide reporting requirements, and it offered a clear, practical overview of the changes coming March 1, 2026. The instructor explained why the new rule is replacing GTOs, how money laundering impacts housing prices, and why the U.S. is moving to mandatory reporting for all-cash residential purchases made by entities or trusts.

The class broke down what must be disclosed—beneficial owners, payment information, and basic transaction details—and clarified that settlement agents will carry the reporting responsibility. Exceptions, like the 25% ownership threshold and personal-name/title situations, were explained in simple terms.

A major takeaway was how much information will now be required from buyers, sellers, and entity members, including detailed banking sources and identification. The proposed form has 111 fields, and title companies expect a $350–$400 buyer fee. Frequent investors won’t be able to reuse forms due to liability concerns.

We also covered what qualifies as an “all-cash” transaction, which includes loans from institutions without AML obligations, and which types of property and transfers are exempt. The session ended with a reminder that penalties for non-compliance can be significant.

Overall, the class was concise, informative, and a helpful guide to preparing for the changes coming to cash real estate transactions.

Kipp Harris, 2026 CE Task Force Chair