The rule is designed to prevent money laundering and increase transparency in real estate transactions by identifying the true individuals behind LLCs, corporations, and trusts used to purchase property.
As Realtors®, you are not typically the ones filing the report. That responsibility typically falls on the closing or settlement agent based on FinCEN’s reporting cascade. But the rule will impact your conversations with clients — especially early in the relationship.
That’s why Minnesota Realtors®, in collaboration with our Forms Committee, created a FinCEN Reporting Notice. It's a simple disclosure form to help you:
- Inform clients early about the new federal requirements,
- Set expectations for information collection, and
- Reduce confusion at closing.
Download a ‘sample’ version of the Notice Regarding Federal FinCEN Reporting Requirements.
The form will be available for use via LoneWolf Transaction Desk, beginning February 28, 2026.
We recommend giving this notice as soon as you start working with buyers or sellers who may use an LLC, corporation, or trust — or anyone planning an all-cash or privately financed transaction. Setting expectations upfront protects both you and your clients.
The new FinCEN rule is a shift, but with early communication and the right tools, Minnesota Realtors® can lead clients through the process with confidence. For more guidance, click here or contact our Legal Hotline.
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