Client Alert Update –
Regarding FinCEN’s Residential Reporting Rule
On May 15, 2026, the Financial Crimes Enforcement Network (“FinCEN”) filed a notice of appeal to the Texas Eastern District Court’s order from March 19, 2026.
The Court’s March 26 Order stayed FinCEN’s Residential Real Estate Reporting Rule from going into effect. Following the filing of the notice of appeal, FinCEN has reaffirmed that no reporting is currently required under the Residential Real Estate Reporting Rule and that there will not be any liability for not reporting at this time.