Since March 1, 2026, the Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Treasury, has required reporting of many residential real estate transfers to legal entities and trusts. Knowing whether your closing is covered, and gathering the information early, prevents delays.

Which transfers are covered

The rule generally applies when both of these are true:

The property is residential: one- to four-family homes, condominiums, townhomes and cooperative units, and certain land intended for such housing.
The buyer is a legal entity (such as an LLC or corporation) or a trust, and the purchase is non-financed. A purchase counts as non-financed unless it's financed by a lender that is itself subject to federal anti-money-laundering rules. All-cash, private-lender and seller-financed purchases can all be covered.

Purchases by individuals in their own names, and most transfers with a traditional bank mortgage, are not reported under this rule.

Common exemptions

Among others: transfers on death or through inheritance, divorce-related transfers, transfers to a bankruptcy estate, court-supervised transfers, and transfers for no consideration by an individual to their own trust.

Who files

A "reporting person," usually the closing or settlement agent, files the report. That's typically the title company, though in some transactions an attorney or other professional has the responsibility.

What information is needed

The report includes details about the property, the seller, the buyer entity or trust, and the buyer's beneficial owners, meaning individuals who own 25% or more or exercise substantial control, along with trustees and certain beneficiaries. It also covers the price and how it was paid. The buyer certifies the beneficial ownership information.

How to avoid delays

Tell your attorney and title company early if you're buying through an LLC or trust
Have entity documents, trust documents and owner information ready
Know which accounts the funds are coming from
Allow time before closing to complete the certifications

Final thoughts

The rule adds paperwork for entity and trust buyers, but early preparation keeps closings on schedule. If you're buying through an LLC or trust, see closings or schedule a consultation.

By Attorney Shara Kamal. General information for Illinois readers; not legal advice for a specific situation.