
FinCEN's Residential Real Estate Rule Is Vacated: What All-Cash Closings Still Require in 2026
A federal court in the Eastern District of Texas vacated FinCEN's Residential Real Estate Reporting Rule nationwide on March 19, 2026, one day before it took effect, and FinCEN's May 18, 2026 FAQs confirm no Real Estate Report is required and no retroactive filing will be demanded if the Fifth Circuit reverses. The Geographic Targeting Orders were untouched and still bind title insurers in covered metros, so this guide covers the rule's three-part test (residential, non-financed, entity or trust buyer), the seven-step reporting-person cascade, and the intake, retention, and reinstatement-kit practices closing professionals should keep dormant rather than delete.










