Our Focus During the FinCEN Pause
Our Commitment During the Pause
Our focus during this time is continuing to support you with updates, guidance, and resources while making it no-cost to continue ordering reports and keeping them at Clear to Close status. That way you are ready when the regulation resumes without losing your compliance workflows. We do not bill for reports or consume credits until we file, and we are absorbing the cost of maintaining compliance for you during this pause. Continued support and keeping up with your needs during the pause is our highest priority right now. Below we address the current situation, what comes next, and common billing questions.
Where things stand
The government filed its notice of appeal on May 11, 2026, taking the Flowers vacatur to the Fifth Circuit. Separately, Fidelity National Financial filed its own appeal in the Eleventh Circuit on April 17 after losing its challenge to the rule in the Middle District of Florida. Both cases are now on appeal in two different circuits, with opposite outcomes at the district level. The rule remains paused while these appeals proceed.
What typically happens next
With the appeal now filed, the next step to watch for is a government motion asking the Fifth Circuit to stay the vacatur and reinstate the rule while the appeal plays out. When CTA reporting was paused by this same court, the Fifth Circuit lifted the pause by day twenty and the Supreme Court stayed the injunction by day fifty-one. If the government moves on a similar timeline, the rule could resume within weeks. The Fidelity appeal in the Eleventh Circuit adds a second track that could result in a circuit split, the most common path to Supreme Court review.
What we're doing during the pause
We are actively rolling out features to help you manage the pause, including a dashboard toggle to pause customer reminders without cancelling reports, the ability to cancel and recover reports, and continued improvements based on feedback in preparation for a resumption of the rule. We are not less busy. We are more so, keeping up with the needs coming from this case along with our existing roadmap. We will continue shipping updates throughout the pause.
Billing and refunds
For pay-later plans, we do not bill unless we file. Keeping reports at Clear to Close and using the platform to stay prepared costs you nothing. No invoices are generated during the pause for reports that have not been filed.
For prepaid plans, credits are not consumed until a report is marked closed, so no credits are being drawn during the pause. To account for the time lost during this period, we are extending all prepaid report credit expirations by two months effectively immediately. We estimate this to be longer than the pause itself so your credits are protected regardless of how quickly the appeals process moves.
It is very early in this process and we are not prioritizing policy updates around refunds at this time. We expect the rule to resume and are building to keep you ready for that.
How to stay updated
Please feel free to reach out to [email protected] with any questions. We understand this is a confusing and uncertain time for everyone in the industry. We are here, we are watching this closely, and we will continue to assist and update you every step of the way.
