source:
  type: regulation
  id: fincen-rre-31cfr-1031-320
  authority: FinCEN Anti-Money Laundering Regulations for Residential Real Estate Transfers (31 CFR 1031.320)
  status: vacated-watch
  description: FinCEN final rule, 89 FR 70258 (Aug 29, 2024), 31 CFR 1031.320 — a streamlined SAR "Real Estate Report" for non-financed transfers of residential real property to legal entities and trusts. Compliance date was delayed to Mar 1, 2026, then the rule was VACATED nationwide (E.D. Texas, Mar 19, 2026); FinCEN appealed. NOT currently required. Tracked here for readiness in case it is reinstated on appeal.
obligations:
- id: fincen-rre-real-estate-report
  canonical_id: fincen-rre-real-estate-report
  section: 'FinCEN RRE — WATCH (VACATED): Real Estate Report on non-financed residential transfers to entities/trusts'
  description: WATCH (rule VACATED Mar 19, 2026; FinCEN appealed — NOT currently required). The rule would require reporting persons to file a "Real Estate Report" on certain non-financed transfers of residential real property to legal entities and trusts.
  type: proposed
  audit_question: If the RRE rule is reinstated on appeal, could [LENDER] identify reportable non-financed transfers and file the Real Estate Report?
  workflow_phase: compliance
  owner_role: bsa_officer
  secondary_owner_role: cco
  cadence: monitor
  consequence: Acting on stale or un-finalized requirements creates legal exposure; failing to track them forfeits lead time.
  tags:
  - fincen
  - rre
  - bsa
  - aml
  - watch
  - vacated
  - real-estate-report
  - monitor
  primary_source:
    tier: 1
    authority: FinCEN Anti-Money Laundering Regulations for Residential Real Estate Transfers (89 FR 70258, Aug 29, 2024) — 31 CFR 1031.320
    source_class: federal-register
    source_url: https://www.federalregister.gov/documents/2024/08/29/2024-19198/anti-money-laundering-regulations-for-residential-real-estate-transfers
    snapshot_id: 8584e0043149a961
    fetched_at: '2026-06-08T00:00:00Z'
    content_hash: sha256:placeholder-snapshot-content-hash-from-source-json
    paragraph_quote: The final rule imposes a streamlined suspicious activity report (SAR) filing requirement under which reporting persons, as defined, are required to file a “Real Estate Report” on certain non-financed transfers of residential real property to legal entities and trusts.
    drafter_attestation: Verbatim from FinCEN RRE final rule snapshot. Core reporting requirement — currently vacated.
  program_review: Does the program track the vacated RRE rule on appeal and hold a readiness plan to file Real Estate Reports if it is reinstated?
  file_review: 'WATCH — VACATED, no in-force duty. Readiness only: could the closing/settlement workflow identify reportable transfers if reinstated.'
  judgment: false
- id: fincen-rre-scope-non-financed
  canonical_id: fincen-rre-scope-non-financed
  section: 'FinCEN RRE — WATCH (VACATED): scope — non-financed transfers to entities/trusts; transfers to individuals not covered'
  description: WATCH (vacated). The rule covers certain non-financed transfers of residential real property to specified legal entities and trusts on a nationwide basis; transfers made directly to an individual are not covered.
  type: proposed
  audit_question: Does [LENDER] understand the RRE scope (non-financed transfers to entities/trusts; individual transfers excluded) for readiness if reinstated?
  workflow_phase: compliance
  owner_role: bsa_officer
  secondary_owner_role: cco
  cadence: monitor
  consequence: Acting on stale or un-finalized requirements creates legal exposure; failing to track them forfeits lead time.
  tags:
  - fincen
  - rre
  - bsa
  - aml
  - watch
  - vacated
  - scope
  - monitor
  primary_source:
    tier: 1
    authority: FinCEN Anti-Money Laundering Regulations for Residential Real Estate Transfers (89 FR 70258, Aug 29, 2024) — 31 CFR 1031.320
    source_class: federal-register
    source_url: https://www.federalregister.gov/documents/2024/08/29/2024-19198/anti-money-laundering-regulations-for-residential-real-estate-transfers
    snapshot_id: 8584e0043149a961
    fetched_at: '2026-06-08T00:00:00Z'
    content_hash: sha256:placeholder-snapshot-content-hash-from-source-json
    paragraph_quote: require certain persons involved in real estate closings and settlements to submit reports and keep records on certain non-financed transfers of residential real property to specified legal entities and trusts on a nationwide basis. Transfers made directly to an individual are not covered by this rule.
    drafter_attestation: Verbatim from FinCEN RRE final rule snapshot. Scope of covered transfers — currently vacated.
  program_review: Does the program understand the covered-transfer scope for readiness?
  file_review: 'WATCH — VACATED. Readiness only: scope understanding.'
  judgment: false
