Why Some Real Estate Closings Will Look Different in 2026

*A new federal reporting requirement affects certain entity and cash transactions nationwide, including St. Louis.*

Not every change in real estate shows up in market statistics or price charts. Some changes are procedural, happening quietly behind the scenes, and only become noticeable when a transaction suddenly feels more complicated than expected.

A new federal reporting rule from the U.S. Treasury Department’s Financial Crimes Enforcement Network, commonly referred to as FinCEN, falls squarely into that category. While it has been discussed for some time at the national level, it is now close enough to implementation that buyers, sellers, and investors in the St. Louis area should be aware of what is coming.

What is changing

FinCEN has adopted a Residential Real Estate Reporting Rule that expands federal reporting requirements for certain residential real estate transfers. The rule is designed to increase transparency when residential property is purchased by a legal entity or trust without the use of traditional mortgage financing.

In the past, similar reporting requirements existed only through temporary Geographic Targeting Orders that applied to specific markets and price ranges. This new rule is different. It is nationwide and intended to be permanent.

Although the rule was originally scheduled to take effect December 1, 2025, FinCEN has announced a delayed compliance date of March 1, 2026.

Which transactions are affected

The rule applies to residential real estate with one to four units when the buyer is a legal entity or trust and the purchase is not financed through a traditional lender.

In those situations, additional information about the individuals associated with the purchasing entity must be reported as part of the closing process.

Owner-occupied purchases using standard mortgage financing are generally not affected.

Why this matters in the St. Louis market

The St. Louis market includes a steady mix of investment properties, LLC and trust ownership structures, and cash or privately financed transactions. Because of that, this rule will be relevant to a meaningful portion of local deals, even though it will not apply to every buyer or seller.

For buyers using an entity or trust, the change may mean additional documentation and review steps before closing. For sellers, it may help explain why certain transactions take longer to reach the closing table than expected.

The reporting obligation itself will fall primarily on settlement professionals such as title companies and closing agents, but the impact is felt throughout the transaction timeline. Deals that are not prepared for the added requirements are more likely to experience delays.

What buyers and sellers should know now

This rule does not change who can buy property, what types of properties can be purchased, or how values are determined. It changes how certain transactions are documented and reviewed.

Buyers and sellers involved in entity or trust purchases are best served by addressing ownership structure early in the process and allowing enough time for compliance requirements to be handled properly. As with most regulatory changes, the smoothest transactions tend to be the ones where expectations are set well before closing day.

This is not a market shift. It is a procedural one.

As the March 2026 compliance date approaches, awareness and preparation will matter more than urgency. Understanding how this rule applies can help prevent last-minute surprises and keep transactions on track.

If you are buying or selling in the St. Louis area and your transaction involves an LLC, trust, or investment property, this is exactly the kind of detail that should be discussed early, not discovered at the closing table. I work with buyers and sellers across Kirkwood and the greater St. Louis area and make it a priority to stay ahead of regulatory changes that can affect real-world transactions. When you understand the process going in, you are far more likely to have a smooth closing coming out.

📲 Contact me today to put a plan in motion — and let’s make your next move your smartest one yet.
Karen Moeller
Karen.Moeller@stlre.com
314.678.7866
Connect with Karen Moeller

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