FinCEN Compliance Reports

Starting March 1, 2026, title companies and settlement agents must file a new FinCEN Real Estate Report for qualifying non-financed residential transactions involving legal entities and trusts. For busy title teams, this means collecting sensitive beneficial ownership data, tracking which files trigger reporting, and meeting strict filing deadlines — all without slowing down closings.

Skyline Title Support offers a turnkey FinCEN compliance service designed to handle the operational burden for you. We collect the required beneficial owner information, track reportable transactions, and file the Real Estate Report through FinCEN's BSA E-Filing system — so your team stays focused on closings while staying fully compliant.

Order FinCEN Compliance Reports the same way you order municipal lien searches, estoppels, and other title services — directly through the Skyline portal.

Skyline provides operational compliance support services. This content is not legal advice.
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What Transactions Require FinCEN Reporting?

The new rule targets a specific set of transactions. Understanding which files are in scope is the first step to building a reliable compliance workflow.

Reporting IS required when:

Non-financed (cash) transfer of residential real property
Buyer is a legal entity — LLC, corporation, partnership, or similar
Buyer is a trust (with limited exceptions)
Beneficial ownership information must be disclosed

Generally NOT Required

Buyer is a natural person (individual)
Transaction involves a traditional mortgage or institutional lender
Exempt transfers (e.g., estate planning, divorce-related)

Why Title Companies Are Preparing Now

The March 1, 2026 effective date isn't a suggestion — it's an enforcement deadline. Title companies that wait until reportable files are already in their pipeline risk incomplete data collection, missed filing deadlines, and penalties that start at nearly $1,400 per violation.

The Real Estate Report includes up to 111 data fields. Collecting beneficial ownership details requires coordination with buyers, their representatives, and sometimes their legal counsel — all while keeping the closing on track.


Skyline's compliance service turns this from a scramble into a structured workflow, so your team has a repeatable process from day one.

111
Data fields per report
800K+
Transactions impacted annually
5 Years
Record retention required

How Skyline Handles FinCEN Compliance for You

STEP 1
Identify Reportable Transactions
We help you flag files that meet FinCEN’s reporting criteria — entity or trust buyers in non-financed transactions — so nothing slips through the cracks.
STEP 2
Collect Beneficial Owner Data
Skyline manages the collection of all required information — names, dates of birth, addresses, citizenship, and taxpayer identification numbers — directly from beneficial owners, entities, and their representatives.
STEP 3
Prepare & File the Real Estate Report
We compile the data, verify completeness, and file the required Real Estate Report through FinCEN’s BSA E-Filing system — on time, every time.
STEP 4
Maintain Compliance Records
Skyline provides structured documentation and supports the 5-year record retention requirement, giving you a clean audit trail for every reportable transaction.

The Cost of Non-Compliance

FinCEN takes reporting obligations seriously. Title companies that fail to file — or file incomplete reports — face escalating consequences:

~$1,400

Per violation for incomplete or late filings

$108,489

Maximum for negligent patterns of non-compliance

$250,000

Plus up to 5 years imprisonment for willful violations

Penalties apply per transaction. For a title company handling dozens of qualifying transactions per month, exposure adds up fast. Skyline's service is designed to prevent the operational gaps that lead to missed filings.

The #1 Title Support Platform for FinCEN Compliance Reports

We offer comprehensive services that cover
all aspects of title support

Why Title Companies Choose Skyline for FinCEN Compliance

Most title companies don’t have the bandwidth to build a FinCEN compliance workflow from scratch — and they shouldn’t have to. Skyline brings the same reliability and responsiveness you know from our municipal lien searches, estoppels, and title services to this new compliance requirement.

● Purpose-Built Service: Not a bolt-on feature. Our FinCEN compliance offering is designed specifically for title company workflows.

● Data Collection Expertise: We handle the sensitive outreach to beneficial owners, so your closers don’t have to.

● Filing Accuracy: Every report is reviewed for completeness before submission to FinCEN’s BSA E-Filing system.

● Real People, Real Support: You get responsive communication from a team that understands title workflows — not a chatbot.

● Portal Ordering: Place FinCEN compliance orders the same way you order lien searches and estoppels — through the Skyline portal.
SEAMLESS SOFTWARE CONNECTIONS

Supported Integrations

The following applications support FinCEN Compliance Reports
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Frequently Asked Questions

 Feel free to contact us if you have any other other questions
Who is required to file FinCEN Real Estate Reports?
The closing or settlement agent listed on the settlement statement is typically the responsible reporting party. FinCEN uses a priority cascade to determine responsibility. The reporting obligation generally applies to non-financed residential transfers involving legal entities (LLCs, corporations, partnerships) or trusts as buyers.
When does the requirement take effect?
The new reporting requirement takes effect March 1, 2026. It applies to qualifying transactions occurring on or after that date. Title companies should have their compliance process in place before March to avoid scrambling on live files.
What are the filing deadlines?
Reports must be filed by the last day of the month following the closing, or 30 calendar days after closing — whichever is later. Skyline’s workflow is designed to keep you ahead of these deadlines.
Does this apply to all cash transactions?
It applies to non-financed transactions — meaning no institutional lender is involved. Transactions with a traditional mortgage are generally not in scope. If the financing comes from a lender not subject to AML/CFT requirements, FinCEN may still treat it as non-financed.
Does this apply to individual buyers?
No. Purchases by natural persons (individual buyers) are exempt. The rule targets transfers to legal entities and trusts.
What are the penalties for non-compliance?
Incomplete or late filings can result in civil penalties starting at approximately $1,400 per violation, up to $108,489 for negligent patterns. Willful violations carry penalties up to $250,000 and up to 5 years imprisonment. We recommend consulting legal counsel for interpretation specifics.
Does Skyline take on the legal reporting liability?
Under the FinCEN rule, the title company remains the designated “Reporting Person” and retains ultimate legal responsibility. Skyline acts as your operational compliance partner, we collect the required information, prepare, and submit the report on your behalf. If a penalty is assessed solely due to Skyline’s proven administrative filing error, and accurate, timely information was provided by the Client, Skyline will reimburse the documented penalty amount. Liability is limited to the fees paid for the specific report.
Can Skyline file the report on our behalf?
Yes. Skyline’s service includes filing the Real Estate Report through FinCEN’s BSA E-Filing system. We handle the data compilation, completeness verification, and submission. Your team maintains oversight of the process.
How do I order this service?
Place FinCEN Compliance Report orders through the Skyline portal, the same way you order municipal lien searches, estoppels, and other title services. You can also order directly through Qualia, with additional integrations coming shortly thereafter. Contact us for a quote and we will walk you through setup.

Be FinCEN-Ready Before March 1st

Don’t wait for reportable files to hit your desk. Get your compliance workflow in place now.