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FinCEN’s Residential Real Estate Reporting Rule Is Now in Effect: Assessing Compliance Obligations and Associated Risk

2026-03-26 13:00:00

1.5 hours

2026-03-26 13:00:00

Over 1,000+ webinars

FinCEN’s Residential Real Estate Reporting Rule is now live, creating essential federal anti-money laundering compliance obligations for attorneys handling residential closings.

2026-03-26 13:00:00

1.5 hours

FinCEN’s Residential Real Estate Reporting Rule is now live, creating essential federal anti-money laundering compliance obligations for attorneys handling residential closings.

2026-03-26 13:00:00

1.5 hours

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Course Overview

FinCEN’s Residential Real Estate Reporting Rule now in effect as of March 1, 2026

With FinCEN’s Residential Real Estate Reporting Rule now in effect as of March 1, 2026, attorneys must navigate brand-new federal reporting obligations that fundamentally reshape closing practices and professional liability exposure. This program delivers a post-implementation analysis focused on what’s happening in the first weeks of enforcement. Attendees will gain practical guidance on determining reportable transactions, allocating filing responsibility, managing beneficial ownership documentation, and protecting against malpractice risk.

Determining Reportability

Learn how to analyze complex deal structures and avoid costly mistakes when transactions fall into uncertain or layered entity scenarios.

Filing Responsibility

Understand designation agreements, disputes among closing parties, and the steps attorneys should take to document and shift risk appropriately.

Beneficial Ownership

Navigate layered entities and trust structures while clarifying how much verification is truly required and how to defensibly document your file.

Malpractice & Penalties

Identify where liability arises if a report is missing or inaccurate, and understand the civil, criminal, and recordkeeping risks regulators are likely to target first.

Course Overview

FinCEN’s Residential Real Estate Reporting Rule now in effect as of March 1, 2026

With FinCEN’s Residential Real Estate Reporting Rule now in effect as of March 1, 2026, attorneys must navigate brand-new federal reporting obligations that fundamentally reshape closing practices and professional liability exposure. This program delivers a post-implementation analysis focused on what’s happening in the first weeks of enforcement. Attendees will gain practical guidance on determining reportable transactions, allocating filing responsibility, managing beneficial ownership documentation, and protecting against malpractice risk.

Determining Reportability

Learn how to analyze complex deal structures and avoid costly mistakes when transactions fall into uncertain or layered entity scenarios.

Filing Responsibility

Understand designation agreements, disputes among closing parties, and the steps attorneys should take to document and shift risk appropriately.

Beneficial Ownership

Navigate layered entities and trust structures while clarifying how much verification is truly required and how to defensibly document your file.

Malpractice & Penalties

Identify where liability arises if a report is missing or inaccurate, and understand the civil, criminal, and recordkeeping risks regulators are likely to target first.

Why Attend

Why this 
program matters

FinCEN’s Residential Real Estate Rule is live, creating compliance exposure for attorneys handling covered transactions.
30%
Repeat home buyers paid all cash (no financing), making cash transactions a primary focus of FinCEN’s reporting framework. Source: National Association of Realtors (NAR) 2025 Profile of Home Buyers and Sellers.
$71K
Maximum civil penalty range for willful Bank Secrecy Act violations ranges from $71,545 to $286,184, adjusted for 2025 inflation. Source: FinCEN Residential Real Estate Rule enforcement guidance.
17.4B
More than $53.7 billion in suspicious real estate activity identified in Bank Secrecy Act reports related to money laundering networks. Source: FinCEN analysis on suspected money laundering in residential real estate.
$0
There is no minimum purchase price threshold for covered transactions, meaning attorneys must screen and document compliance consistently even in lower-dollar deals.

Agenda

Session 1

Post-Implementation Reality: What's Changed & Early Compliance Challenges

Session 2

Determining Reportability in Complex Transactions

Session 3

Filing Responsibility, Beneficial Ownership & Reasonable Reliance

Session 4

Malpractice Exposure, Penalties & Enforcement Risk

clock 1:00 pm - 1:15 pm EST

Post-Implementation Reality: What's Changed & Early Compliance Challenges

Alan Winston Granwell

Holland & Knight

Bruce Zagaris

Berliner Corcoran & Rowe

Peter Hardy

Holland & Knight

Michael C. Titens

Holland & Knight

A practical look at how the Rule has been functioning since March 1, 2026, including workflow disruptions, intake slowdowns, and the real-world friction attorneys are encountering in the first phase of reporting.

Alan Winston Granwell

Holland & Knight

Bruce Zagaris

Berliner Corcoran & Rowe

Peter Hardy

Holland & Knight

Michael C. Titens

Holland & Knight

clock 1:15 pm - 1:30 pm EST

Determining Reportability in Complex Transactions

Alan Winston Granwell

Holland & Knight

Bruce Zagaris

Berliner Corcoran & Rowe

Peter Hardy

Holland & Knight

Michael C. Titens

Holland & Knight

How to analyze gray-area deals, layered entity purchases, trust structures, and nontraditional transfers to confidently determine when a filing is required and when it is not.

Alan Winston Granwell

Holland & Knight

Bruce Zagaris

Berliner Corcoran & Rowe

Peter Hardy

Holland & Knight

Michael C. Titens

Holland & Knight

clock 1:30 pm - 2:00 pm EST

Filing Responsibility, Beneficial Ownership & Reasonable Reliance

Alan Winston Granwell

Holland & Knight

Bruce Zagaris

Berliner Corcoran & Rowe

Peter Hardy

Holland & Knight

Michael C. Titens

Holland & Knight

Who must file, how designation agreements work, how to manage disputes among closing parties, and how to collect and document beneficial ownership information while properly relying on client-provided data.

Alan Winston Granwell

Holland & Knight

Bruce Zagaris

Berliner Corcoran & Rowe

Peter Hardy

Holland & Knight

Michael C. Titens

Holland & Knight

clock 2:10 pm - 2:40 pm EST

Malpractice Exposure, Penalties & Enforcement Risk

Alan Winston Granwell

Holland & Knight

Bruce Zagaris

Berliner Corcoran & Rowe

Peter Hardy

Holland & Knight

Michael C. Titens

Holland & Knight

Where attorneys face professional liability if a report is missed or inaccurate, what civil and criminal penalties apply, recordkeeping obligations, and where regulators are most likely to focus enforcement.

Alan Winston Granwell

Holland & Knight

Bruce Zagaris

Berliner Corcoran & Rowe

Peter Hardy

Holland & Knight

Michael C. Titens

Holland & Knight

01 04
Prev
Next

Key topics that will be covered

What will you learn

This CLE examines the operational and liability implications of FinCEN's Residential Real Estate Reporting Rule now that it is in effect. The program analyzes how the Rule integrates into residential closing workflows, including transaction screening, ownership identification, and federal filing mechanics. Attendees will review interpretive challenges that have surfaced in early implementation and examine how reporting obligations intersect with existing real estate practice structures. Civil penalty exposure and compliance infrastructure expectations are also addressed.

What will you gain

Participants will gain a practical framework for incorporating federal reporting requirements into their real estate practice without unnecessary disruption. The program provides concrete strategies for evaluating transactions, coordinating with closing participants, strengthening documentation processes, and reducing risk exposure. Attorneys will leave better equipped to manage compliance efficiently while protecting their firms from avoidable financial and regulatory consequences.

Operational Changes
How federal reporting requirements affect intake, diligence, and deal timelines.
Covered Transactions
Applying the Rule to complex ownership structures and nontraditional transfers.
Reporting Responsibility
Coordinating with other closing professionals to reduce compliance gaps and disputes.
Beneficial Ownership
Addressing layered entities and trust arrangements in practice.
Documentation Standards
Building defensible files that support reporting decisions.
Penalty Exposure
Understanding financial risk and likely areas of regulatory focus.

What will you learn

This CLE examines the operational and liability implications of FinCEN's Residential Real Estate Reporting Rule now that it is in effect. The program analyzes how the Rule integrates into residential closing workflows, including transaction screening, ownership identification, and federal filing mechanics. Attendees will review interpretive challenges that have surfaced in early implementation and examine how reporting obligations intersect with existing real estate practice structures. Civil penalty exposure and compliance infrastructure expectations are also addressed.

What will you gain

Participants will gain a practical framework for incorporating federal reporting requirements into their real estate practice without unnecessary disruption. The program provides concrete strategies for evaluating transactions, coordinating with closing participants, strengthening documentation processes, and reducing risk exposure. Attorneys will leave better equipped to manage compliance efficiently while protecting their firms from avoidable financial and regulatory consequences.

Plans

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Price
$95 – $245
Price varies based
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Custom
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Number of Available Webinars 1 1,000+ 1,000+
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Earn "Live" CLE credit Included Included Included
Ability to Ask Questions During
the Presentation via a Chat Box
Included Included Included
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Exclusive Partner Webinars & Events Included Included
Special credits (Ethics, Elimination
of Bias, etc.)
Included Included
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Individual Purchase
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Corporate CLE Plan
$95 – $245
Price varies based
on the course duration
of 1 to 3+ hours
Access type Pay per
class
Number of Available Webinars 1
Number of New Webinars Added Yearly Limited
Earn "Live" CLE credit Included
Ability to Ask Questions During
the Presentation via a Chat Box
Included
Attend "Live" Re-Broadcasts Included
Exclusive Partner Webinars & Events
Special credits (Ethics, Elimination
of Bias, etc.)
Instant Certificates After Completion
Personalized CLE Platform
Live Conferences
Bootcamps

speakers

Joe Ervin

The Law Firm for Truck Safety, LLP
A Partner at The Law Firm for Truck Safety. He focuses exclusively on cases involving commercial motor vehicle crashes and wrongful death. Joe also holds a valid class “A” commercial driver’s license with endorsements for double/triple trailers and tankers.

Education & Credentials

A 2013 graduate of the Gerry Spence Trial Lawyers College in Dubois, Wyoming, Joe is rated AV Preeminent™ by Martindale-Hubbell — the highest peer rating for exceptional legal ability and ethics. He is among the first nine attorneys nationwide to earn board certification in Truck Accident Law from the National Board of Trial Advocacy.

Recognition & Leadership

Joe received the Roadway Safety Award from the American Association for Justice (AAJ) for his commitment to improving highway safety.
 He currently serves as Co-Chair of the Academy of Truck Accident Attorneys (ATAA) Safety Committee, advocating for higher safety standards across the trucking industry.

Professional Involvement

Joe serves on the faculty of the AAJ Advanced Trial Advocacy College: Litigating Truck Collision Cases (2015 & 2024).
 He is an active member of AAJ’s Trucking Litigation Group and sits on the Board of Regents for the Academy of Truck Accident Attorneys.

Experience

Joe frequently consults and co-counsels on complex commercial truck cases. His proven track record includes numerous successful trials against motor carriers and truck leasing companies — delivering justice for victims of commercial vehicle accidents.

Kevin Foley

Reminger Co
A Partner at The Law Firm for Truck Safety. He focuses exclusively on cases involving commercial motor vehicle crashes and wrongful death. Joe also holds a valid class “A” commercial driver’s license with endorsements for double/triple trailers and tankers.

Education & Credentials

A 2013 graduate of the Gerry Spence Trial Lawyers College in Dubois, Wyoming, Joe is rated AV Preeminent™ by Martindale-Hubbell — the highest peer rating for exceptional legal ability and ethics. He is among the first nine attorneys nationwide to earn board certification in Truck Accident Law from the National Board of Trial Advocacy.

Recognition & Leadership

Joe received the Roadway Safety Award from the American Association for Justice (AAJ) for his commitment to improving highway safety.
 He currently serves as Co-Chair of the Academy of Truck Accident Attorneys (ATAA) Safety Committee, advocating for higher safety standards across the trucking industry.

Professional Involvement

Joe serves on the faculty of the AAJ Advanced Trial Advocacy College: Litigating Truck Collision Cases (2015 & 2024).
 He is an active member of AAJ’s Trucking Litigation Group and sits on the Board of Regents for the Academy of Truck Accident Attorneys.

Experience

Joe frequently consults and co-counsels on complex commercial truck cases. His proven track record includes numerous successful trials against motor carriers and truck leasing companies — delivering justice for victims of commercial vehicle accidents.

Grant H. Lawson

The Law Firm for Truck Safety, LLP
A Partner at The Law Firm for Truck Safety. He focuses exclusively on cases involving commercial motor vehicle crashes and wrongful death. Joe also holds a valid class “A” commercial driver’s license with endorsements for double/triple trailers and tankers.

Education & Credentials

A 2013 graduate of the Gerry Spence Trial Lawyers College in Dubois, Wyoming, Joe is rated AV Preeminent™ by Martindale-Hubbell — the highest peer rating for exceptional legal ability and ethics. He is among the first nine attorneys nationwide to earn board certification in Truck Accident Law from the National Board of Trial Advocacy.

Recognition & Leadership

Joe received the Roadway Safety Award from the American Association for Justice (AAJ) for his commitment to improving highway safety.
 He currently serves as Co-Chair of the Academy of Truck Accident Attorneys (ATAA) Safety Committee, advocating for higher safety standards across the trucking industry.

Professional Involvement

Joe serves on the faculty of the AAJ Advanced Trial Advocacy College: Litigating Truck Collision Cases (2015 & 2024).
 He is an active member of AAJ’s Trucking Litigation Group and sits on the Board of Regents for the Academy of Truck Accident Attorneys.

Experience

Joe frequently consults and co-counsels on complex commercial truck cases. His proven track record includes numerous successful trials against motor carriers and truck leasing companies — delivering justice for victims of commercial vehicle accidents.

Alan Winston Granwell

Holland & Knight

Bruce Zagaris

Berliner Corcoran & Rowe

Peter Hardy

Holland & Knight

Michael C. Titens

Holland & Knight

Alan Winston Granwell

Holland & Knight

An attorney with more than 50 years of experience in international taxation, representing multinational corporations and globally oriented high-net-worth clients in international tax planning, compliance and controversy matters.

Recognition & Leadership

Fellow of the American College of Tax Counsel and a well-known, frequent commentator and lecturer on international tax matters. Has authored numerous articles for publications both in the United States and abroad.

Professional Involvement

Active member of STEP, former chair of the Mid Atlantic Branch, current Co-Director of Programs for the Mid Atlantic Branch, and frequent contributor to STEP USA Alerts. Has made presentations for the American Bar Association Section of Taxation, International Bar Association, International Fiscal Association, and STEP.

Experience

In the early 1980s served as International Tax Counsel and Director, Office of International Tax Affairs, U.S. Department of the Treasury, where he was the senior international tax adviser and responsible for directing the U.S. tax treaty program. Began career at Wall Street law firms before government appointment. Previously a tax attorney for a boutique international tax law firm.

Alan Winston Granwell

Holland & Knight

An attorney with more than 50 years of experience in international taxation, representing multinational corporations and globally oriented high-net-worth clients in international tax planning, compliance and controversy matters.

Recognition & Leadership

Fellow of the American College of Tax Counsel and a well-known, frequent commentator and lecturer on international tax matters. Has authored numerous articles for publications both in the United States and abroad.

Professional Involvement

Active member of STEP, former chair of the Mid Atlantic Branch, current Co-Director of Programs for the Mid Atlantic Branch, and frequent contributor to STEP USA Alerts. Has made presentations for the American Bar Association Section of Taxation, International Bar Association, International Fiscal Association, and STEP.

Experience

In the early 1980s served as International Tax Counsel and Director, Office of International Tax Affairs, U.S. Department of the Treasury, where he was the senior international tax adviser and responsible for directing the U.S. tax treaty program. Began career at Wall Street law firms before government appointment. Previously a tax attorney for a boutique international tax law firm.

Bruce Zagaris

Berliner Corcoran & Rowe

Bruce Zagaris advises individuals, entities and governments on international business, especially the regulatory and enforcement aspects, with extensive experience in tax controversy matters, white collar criminal work, and international money movement issues.

Recognition & Leadership

Since 1985, has edited the International Enforcement Law Reporter, a monthly publication.

Professional Involvement

Fluent in Spanish and Portuguese with working knowledge of French.

Experience

Worked on tax controversy matters including representing individuals on voluntary disclosures, audits, and litigation, as well as consulting and serving as an expert witness in criminal trials. Since 1981, has represented foreign governments in international tax and financial services, including advising and helping negotiate income tax, tax information exchange agreements, and bilateral investment treaties. Has handled evidence gathering and extradition cases, prisoner transfer applications, and testified as an expert in international criminal cases involving money laundering and tax crimes. Has trained prosecutors, regulatory, and law enforcement officials on prosecuting money laundering and recovery of assets.

Peter Hardy

Holland & Knight

Peter Hardy is a seasoned white-collar defense attorney and former federal prosecutor who represents corporations and individuals in complex criminal, civil, and regulatory matters nationwide. Based in Holland & Knight’s Philadelphia office, he focuses on white-collar criminal defense, internal investigations, anti-money laundering and Bank Secrecy Act compliance, tax controversy, and related financial enforcement matters.

Education & Credentials

Juris Doctor, cum laude, from the University of Michigan Law School. Bachelor of Arts in Philosophy and Psychology, summa cum laude, from the University of Michigan. Admitted to practice in Pennsylvania and the District of Columbia, as well as before multiple federal courts including the U.S. Tax Court, U.S. District Courts for the Eastern Districts of Pennsylvania and Michigan and the Middle District of Pennsylvania, and the U.S. Courts of Appeals for the Third and Fourth Circuits.

Recognition & Leadership

Ranked by Chambers USA as a leading attorney in Litigation: White-Collar Crime & Government Investigations. Recognized in The Best Lawyers in America for Tax Law, White-Collar Criminal Defense, and Corporate Compliance. Honored by The Legal 500 USA for dispute resolution and corporate investigations. Named a Top Author in White-Collar Defense by the JD Supra Readers' Choice Awards. Received the Outstanding Attorney Award from the DOJ Tax Division.

Professional Involvement

Serves as Co-Chair of the Practising Law Institute's Annual Anti-Money Laundering Program. Fellow of the American College of Tax Counsel. Active member of the American Bar Association's Section of Taxation and the Federal Bar Association's Eastern District of Pennsylvania Federal Criminal Law Committee. Vice-President of the Board of Esperanza Immigration Legal Services. Honorary Board Member of Rebuilding Together Philadelphia.

Experience

Served as an Assistant U.S. Attorney in Philadelphia and as a trial attorney in the U.S. Department of Justice's Tax Division in Washington, D.C., where he prosecuted criminal tax and financial crime cases in federal courts across the country. In private practice, he founded and led anti-money laundering and tax controversy teams. At Holland & Knight, he defends clients in white-collar criminal matters and internal investigations, advises on BSA/AML compliance, and represents clients in civil and criminal tax controversies. Author of Criminal Tax, Money Laundering, and Bank Secrecy Act Litigation.

Michael C. Titens

Holland & Knight

Michael Titens is a corporate attorney who represents U.S. and international clients in structuring, negotiating and implementing mergers and acquisitions as well as joint ventures, with a focus on cybersecurity issues including breach preparedness and responses.

Experience

Represents private equity funds and portfolio companies in formation, financing and M&A transactions. Frequently represents Mexican and other international clients in M&A, foreign investment and other business transactions. Was a resident in the firm's Monterrey, Mexico, office from 1993 to 1997. Previously served as co-chair of the firm's Cybersecurity and Data Privacy Group.

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