Following the March 19, 2026 decision by the U.S. District Court for the Eastern District of Texas in Flowers Title Companies, LLC v. Bessent, the Anti-Money Laundering Regulations for Residential Real Estate Transfers Rule (RRE) has been vacated. The Court determined that FinCEN lacked statutory authority under the Bank Secrecy Act to impose the RRE. FinCEN has indicated it may challenge this ruling, and the rule could be reinstated depending on future court action. As FinCEN stated on March 20, 2026, reporting persons are not currently required to file real estate reports while the order remains in effect. In accordance with guidance from our underwriter, Monaco Cooper Lamme & Carr, PLLC and Maverick Title Services, LLC will immediately pause all related processes—including collecting and reviewing customer information, charging related fees, and preparing or submitting reports to FinCEN—until further notice. We will promptly resume these activities if and when the rule is reinstated.
Our prior update on this FinCEN rule can be found HERE.
