A little clarification.  First, this reporting requirement has been in place for about 9 years in certain geographic areas such as greater New York City, South Florida, (areas where there is a lot of corporate ownership of real estate).

The term "cash sales' does not mean literal cash, it is a purchase by a company for a property with a purchase price over $300,000 without mortgage financing.  The closing agent has to get information on the beneficial owners of the company for the report.

Initially it was a trial program.  However it kept getting extended and additional geographic areas added.  Now it is going nationwide. 

What I would like to see is the dollar amount increased.  A $300,000 all cash condo purchase in 2024 is much more common than it was in 2015.

The title company does that reporting.

Title and escrow are the same for me in my state - CA (by my choice when opening escrow).

Reporting is reporting—no need to report twice. The title company takes care of all the forms.  I am not concerned about this Miss Eileen Burns 954.483.3912 

Thank you for sharing with the AR community. 

Hello Eileen Burns 954.483.3912 this is a great new U.S. rules to combat money laundering.

Eileen Burns 954.483.3912 

Once, a suitcase filled with money was placed on the settlement table. It was immediately whisked away! Within the same year, I received a request to meet with the IRS and the FBI about this transaction. There were lots of questions. I opened my files and showed them what I had as they asked each question. I later heard that the buyer went to a much larger home. It was called The Big House.

This is on the Title Closers. 

 It is part of the upcoming FinCEN Federal Government monstrosity, which will make the IRS look like a charity drive.

   As to this article, when I read "the Biden Administration", and "Janet Yellen" mentioned respectfully,  I wonder exactly who the Florida Realtors  represent. FAR has become a bunch of professional grifters, just like NAR.

attorneys already do this in my state.  They close transactions.

I've only seen "cash" at one closing in my career and the attorney sent her to the bank with her cash to get certified funds.  And a cashier's check or a wire from a bank is not a "cash" transaction.

Just wait til you have to pay for unrealized Capital Gains ! 

You mean Beneficial Ownership filing? Yeah we all did that last year. 

Thank you very much for sharing this link.

Thank you to Kathleen Daniels, Probate & Trust Specialist whose comment is what I would have posted...or something like it.

Kathleen Daniels, Probate & Trust Specialist answered for us Californians nicely in her comment.

Eventually, cash will be reduced & those that have lots of income will be scrutinized. Even further on, a cashless society will take place

Doing whatever they can to keep an eye on those drug dealers. not exactly a new thing, just enlisting another set of eyes on the situation.

Our title companies do that for us here in Colorado.

Odds are the title person or the attorney (depending on your market) will be the one to address this reporting. 

I see this as a necessary extension of the $3m and up money laundering reporting from 2016. I became an agent in early 2016- and one of the key questions I was asking brokers as part of my decision process on which brokerage to join was how they thought this new anti-money laundering (AML to finance people) laws were going to impact the market. Most brokers said it wasn't going to have a significant impact and I eliminated those brokers from further consideration - as they didn't understand what was coming and I did- a correction that hit our market even harder than the Great Recession. That regulation was mostly aimed at NYC, Miami, L.A. and San Francisco. I can't speak to the other cities- but NYC had a lot of overseas buyers that were washing cash via real estate sales- mostly coming from just a few nations. Add all the other regulatory and tax issues since then- and it helps explain why prices today are nearly a lost decade. When we stop adding unnecessary regulation then we will start seeing prices rise again. To be clear- I do think the cash sales report is necessary as I have worked on the other side of this equation in my prior career- though it's not as consequential as the 2016 changes- at least in my market. There are going to be lots of cash sales that don't raise any kind of flag except for the fact that it was an all cash sale. 

Our closings are handled by attorneys and title agents and they would be responsible for those reports.

Retired and reading. The title company will likely be the vehicle to report these types of transactions. Will those wanting to avoid reporting use a shell company to place a mortgage on the property and then pay it off down the road? Will the government audit mortgage providers of there source of funds? Sounds good but more government is usually not a good thing.

Thank you for pointing out the article. Doesn't seem too cumbersome, I don't see the need for a compliance officer, should be easy for a broker to monitor.  We do need to know the mechanism for reporting.  Other industries have had similar requirements for some time now, e.g. banks and car dealerships, I believe, and ours is limited to trusts and entities only.

This is nothing new out here.  The "Greater Los Angeles Region" has been one of the FinCen target markets since the second round (Miami being in phase 1).  Los Angeles has been doing this for 3-4 years now and Florida for 4-5, so this is nothing new.  Escrow is the one who reports it here.

All it is, is a sheet of paper that you have to fill out if you are an entity buyer or seller that lists out the officers of the company.  We already had something similar at the state and federal level to make sure taxes would be getting paid.

That's why everything goes thru atty's here & title company. With cash, buyer & seller split the closing fee.

Title companies do that here, I am pretty sure of.  

New regulations may mean compliance officers are becoming a must-have for every real estate transaction. However, in my view, all that heavy lifting should fall on attorneys, banks, and title companies, not on the real estate agents.

Our role as real estate agents is to facilitate transactions, not to double as compliance officers. The professionals in charge of the legalities and finances have the expertise needed to navigate this complex landscape. They’re the ones who should ensure all the necessary reporting is done.

We should be focused on what we do best—connecting buyers and sellers. Let the attorneys and title companies handle the details regarding cash sales and legal entities. While compliance is crucial, shifting the burden onto trained professionals allows us to provide excellent service without drowning in paperwork.

In the end, it’s all about working together as a team. However, our expertise lies in helping people buy and sell real estate, not in trying to figure out whether someone could be laundering money!

Thank you for sharing this with us and thank goodness for Title Companies!!

My thought is the closing attorney or title company should be responsible for reporting this. Outside of that is should be on the county who records. 

Real Estate Professionals aka agents don't handle every closing transaction.