03/26/2026
In case your head wasn't already spinning over the new FinCEN rules, now it has been suspended!
Following a federal court decision on Thursday vacating FinCEN's Residential Real Estate Reporting Rule, FinCEN today issued guidance confirming that reporting persons are not currently required to file reports under the rule. Click here to read the guidance.
What this means:
• FinCEN has acknowledged the court’s ruling and is not requiring compliance with reporting obligations at this time.
• This reflects the current regulatory posture but may change depending on future legal or administrative developments.
While this guidance provides near-term clarity, uncertainty remains. Future action by FinCEN or the courts could reinstate or modify reporting requirements.
We will continue to engage with FinCEN, monitor legal and regulatory developments and keep you informed as this situation evolves.