FinCEN Postpones Residential Real Estate Reporting Date

In mid-September, in response to a Financial Crimes Enforcement Network (FinCEN) rule requiring collection and reporting of data on certain “all cash” transactions, C.A.R. released a new form titled “Federal Reporting Requirement Purchase Addendum” (C.A.R. form FRR-PA).  The FRR-PA was bundled with the Residential Purchase Agreement (C.A.R. form RPA) and other applicable agreements so that escrow and title companies would have contractual authority to gather and report information for escrows that were scheduled to, or might, close on or after the rule’s scheduled effective date, December 1, 2025.  Implementation of the rule is now delayed until March 1, 2026. 

C.A.R. had intended to update the RPA to include the necessary contractual instructions with the December 2025 forms release and then discontinue the FRR-PA at that time.  Those plans have changed.  The FRR-PA has been updated to reflect the new implementation date, and a revised FRR-PA, with a revision date of 10/25, will be available on zipForm. A change to the RPA addressing the FinCEN rule will not be made in December.  Instead, the FRR-PA will continue in place until the next C.A.R. forms release in June.

For more information, please see the C.A.R. “FinCEN Real Estate Reporting Requirement” Quick Guide.

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