On March 19, 2026, a federal court in Texas vacated FinCEN’s residential real estate reporting rule. FinCEN has confirmed reporting persons are not currently required to file and are not subject to liability for not filing while the order remains in force. FinCEN also notes that 2 other judges have rejected challenges to the rule and that it is appealing the vacatur through DOJ, which filed its opening brief on August 17, 2026 (FinCEN link). FinCEN’s filing system remains open and accepts voluntary filings. Please note: all previously purchased report credits have received a free 9 month expiration extension and now may also be used in our FIRPTA filing feature. Starting reports is free, with no billing or credit use until a report is filed.
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