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Compliance Deadline Approaches for FinCEN’s Residential Real Estate Reporting Requirements

By Marina Olman-Pal, Benjamin G. Greenberg, Melissa Groisman & Tiffanie Monplaisir on February 27, 2026
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single family housing

Effective March 1, 2026, FinCEN’s Residential Real Estate Rule will impose streamlined reporting (the Real Estate Report) and recordkeeping requirements on certain persons involved in residential real estate closings and settlements (collectively, Reporting Persons). FinCEN published the Rule in the Federal Register on Aug. 29, 2024, and released related guidance, including a Fact Sheet and Frequently Asked Questions.

The Residential Real Estate Rule applies to non-financed transfers of residential real property to legal entities and trusts and does not apply to transfers to natural persons.

Although the Rule originally took effect Dec. 1, 2025, FinCEN issued exemptive relief extending the compliance date to March 1, 2026. The reporting requirements apply to reportable transfers that close on or after March 1, 2026.

Link to Click here to read the full GT Alert. Click here to read the full GT Alert.

Photo of Marina Olman-Pal Marina Olman-Pal

Marina Olman-Pal is a Co-Chair of the firm’s Financial Regulatory & Compliance Practice. She advises foreign and U.S. financial institutions on a broad range of U.S. federal and state regulatory and compliance matters including licensing/chartering, acquisitions, mergers, divestitures, third-party risk management and oversight…

Marina Olman-Pal is a Co-Chair of the firm’s Financial Regulatory & Compliance Practice. She advises foreign and U.S. financial institutions on a broad range of U.S. federal and state regulatory and compliance matters including licensing/chartering, acquisitions, mergers, divestitures, third-party risk management and oversight issues, BaaS and other bank/fintech-related matters, compliance with Bank Secrecy Act (BSA)/anti-money laundering (AML) laws and regulations, GENIUS Act and fair access law matters.

Marina counsels a wide range of companies in the financial services sector including, domestic and foreign banks, money services businesses including money transmitters, cryptocurrency businesses, Fintech companies, digital payment companies, and non-financial services companies considering new payment or digital wallet models. Throughout her career, Marina has represented clients before U.S. regulators such as the Federal Reserve, OCC, FDIC, FinCEN, OFAC, the Florida Office of Financial Regulation and other state supervisory authorities. Marina also regularly develops anti-money laundering programs for a wide range of financial services businesses and non-financial services businesses including, U.S. and foreign companies active in industries such as real estate, hospitality, automotive and artificial intelligence, among many others.

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Photo of Benjamin G. Greenberg Benjamin G. Greenberg

Benjamin G. Greenberg is the former U.S. Attorney for the Southern District of Florida. Ben is a seasoned litigator who represents corporations and individuals in criminal and civil government investigations involving the Foreign Corrupt Practices Act (FCPA), health care fraud, SEC matters, financial

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Benjamin G. Greenberg is the former U.S. Attorney for the Southern District of Florida. Ben is a seasoned litigator who represents corporations and individuals in criminal and civil government investigations involving the Foreign Corrupt Practices Act (FCPA), health care fraud, SEC matters, financial institution fraud, money laundering, and the False Claims Act (FCA). Ben’s clients include private equity funds, pharmaceutical and medical device manufacturers, banks, health care providers, and international companies in the technology, financial services, and investment space. Ben also conducts internal corporate investigations and advises clients on a wide array of compliance and regulatory issues. Ben uses his deep government experience and knowledge of international legal matters to help international clients navigate national and local matters involving the Department of Justice, the SEC, foreign governments, and other law enforcement agencies. Ben is also an experienced trial attorney who has tried more than twenty cases to verdict in federal court.

As U.S. Attorney, Ben was the chief federal law enforcement officer for one of the largest and busiest offices in the country, responsible for overseeing more than 200 attorneys and close to 500 employees. In this capacity, Ben worked closely with the Criminal Division and the National Security Division in Washington to supervise high profile and complex cases in South Florida. Ben also traveled abroad to meet with senior law enforcement officials regarding joint investigations and to develop strategies for combating transnational crime.

As U.S. Attorney, Ben oversaw prosecutions under the Foreign Corrupt Practices Act (FCPA) involving the bribery of foreign government officials, securities and financial fraud, a healthcare fraud takedown of 124 defendants responsible for $337 million in false billing, dozens of health care related False Claims Act cases, and national security prosecutions. As a trial attorney, Ben convicted the CEO of a major financial institution for securities fraud, bank fraud, and conspiracy in one of the most noteworthy corporate fraud cases in South Florida history. He also led the extradition and prosecution of Ze’ev Rosenstein in a case of first impression against the leader of one the most dominant Israeli organized crime syndicates.

Prior to law school, Ben was selected as a Rotary Ambassadorial Fellow to study at the Pardes Institute of Jewish Studies in Jerusalem.

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Photo of Melissa Groisman Melissa Groisman

Melissa Groisman is a Miami-based real estate attorney in Greenberg Traurig’s Real Estate Practice. She represents institutional investors, REITs, private investment groups, and developers in complex commercial real estate transactions, including acquisitions, dispositions, financings, and development matters across multifamily, residential, industrial, office, retail…

Melissa Groisman is a Miami-based real estate attorney in Greenberg Traurig’s Real Estate Practice. She represents institutional investors, REITs, private investment groups, and developers in complex commercial real estate transactions, including acquisitions, dispositions, financings, and development matters across multifamily, residential, industrial, office, retail, and alternative asset classes.

With nearly two decades of experience, Ms. Groisman focuses her practice on the structuring and execution of sophisticated real estate transactions and advises clients at all stages of the deal lifecycle, from initial due diligence through closing. She is known for her practical, business-oriented approach and her ability to drive transactions forward, anticipate and resolve deal issues efficiently, and serve as a steady lead on matters involving multiple stakeholders and tight timelines.

Ms. Groisman holds an AV Preeminent® Rating from Martindale-Hubbell, reflecting the highest peer recognition for legal ability and ethical standards. A Miami native with Argentine roots, she is fluent in Spanish and earned her J.D. as a Dean’s Merit Scholar from the University of Miami School of Law and her B.A. from Duke University.

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Photo of Tiffanie Monplaisir Tiffanie Monplaisir

Tiffanie Monplaisir is a member of the Corporate Practice in Greenberg Traurig’s Miami office. She focuses her practice on financial services provider regulation and compliance. Tiffanie counsels U.S. and international financial institutions, non-financial services businesses, and other entities in navigating the complex federal

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Tiffanie Monplaisir is a member of the Corporate Practice in Greenberg Traurig’s Miami office. She focuses her practice on financial services provider regulation and compliance. Tiffanie counsels U.S. and international financial institutions, non-financial services businesses, and other entities in navigating the complex federal and state regulatory landscape governing payments, lending, licensing, and consumer financial services. Tiffanie’s practice includes advising banks, FinTech and digital payment companies, money services businesses, payment processors, cryptocurrency businesses, and digital asset companies on a wide range of regulatory matters including licensing, crafting innovative solutions for Bank Secrecy Act/Anti-Money Laundering (BSA/AML) and Office of Foreign Assets Control (OFAC) compliance programs and related policies and procedures. Tiffanie also works on nationwide state money transmitter, lending, servicing, and other license acquisition projects.

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  • Posted in:
    Real Estate & Construction
  • Blog:
    Financial Services Observer
  • Organization:
    Greenberg Traurig, LLP
  • Article: View Original Source

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