The Washington Report
October 6, 2025
In This Issue:
Anti-Money Laundering and Counter Terrorist Financing
Housing Issues Update
Anti-Money Laundering and Counter Terrorist Financing
FinCEN Residential Rule Postponement and Update
The Financial Crimes Enforcement Network (FinCEN) recently announced the postponement of reporting requirements under the Residential Real Estate Rule until March 1, 2026. The rule goes into effect on December 1, 2025; however, FinCEN is granting exemptive relief under the rule to “allow the industry sufficient time to institute the policies, procedures, and processes necessary to comply.” Reporting persons under the law—primarily title agents, attorneys, and closing agents—will have until March 1, 2026, to begin filing complying with the law.
The Residential Real Estate Rule requires certain professionals report information to FinCEN for non-financed transfers of residential real property to legal entities and trusts. Attorneys and title agents will be primarily responsible for filing the Real Estate Reports, which will require information regarding beneficial owners of the legal entities and trusts. FinCEN issued the final Residential Real Estate Rule in August 2024, and the rule becomes effective on December 1, 2025. After the FinCEN announcement, the compliance and reporting obligations for reporting persons now begin on March 1, 2026.
NAR will continue to provide FinCEN updates, including updates related to the Residential Real Estate Rule.
Learn more about FinCEN's Residential Real Estate Rule.
Housing Issues Update
Government Enters Shutdown
The federal government officially shut down at 12:01 a.m. today, October 1, as Congress failed to pass a funding measure to keep the government open. As a result, many services have been stopped or slowed and federal government employees deemed nonessential will be furloughed. As the federal government operates with reduced capacity, there could be disruptions to some FHA and VA loans; and a pause on USDA rural housing loans is expected. Similarly, the National Flood Insurance Program will not renew or sell new flood insurance policies. For more information on how a government shutdown could affect REALTORS®, see NAR’s resource.