New FinCEN Rule Alert: Big Changes for Buyers Using Trusts & LLCs

If you or your buyer is purchasing residential property in a trust or legal entity, the rules are changing — nationwide.

The Financial Crimes Enforcement Network (FinCEN) rolled out a new reporting framework took effect March 1st, replacing the old Geographic Targeting Orders (GTOs).

Here’s what you need to know:

• No more geographic limits – The rule will apply nationwide (including D.C., Puerto Rico, and tribal lands).

• No purchase price threshold – Unlike prior $300K+ requirements, all qualifying transactions may be reportable.

• Covers residential 1–4 units, condos, co-ops, mixed-use, vacant land for residential builds, and small apartment buildings.

• Applies to non-institutional financing – Cash, private lending, seller financing, or loans not subject to AML reporting.

• Expanded data collection – Title companies will be required to report detailed information on beneficial owners, source of funds, and parties involved.

This is a significant shift — especially for transactions involving trusts and LLCs.

What you need to do:

•  Understand reporting obligations

•  Coordinate with legal and compliance teams

•  Update internal processes

•  Train staff on new documentation requirements

For buyers and agents, this means more transparency, more documentation, and more diligence at closing.

At The David Frank Law Group, we stay ahead of regulatory changes so your transactions stay smooth and compliant.

Have questions about how this impacts your trust or entity purchase? Let’s talk.