New FinCEN anti-money laundering regulations will significantly impact title & escrow operations starting March 1, 2026. To help you navigate these requirements, Qualia has built a new solution directly into our cloud-based title production system. These capabilities help title & escrow companies track, collect, and report the necessary FinCEN information efficiently and securely, giving you peace of mind that no reportable transaction is missed.

“We’re more than a vendor; we’re a partner committed to helping title & escrow companies overcome challenges,” said Brian Thome, Chief Customer Officer at Qualia. “That’s why we built these features directly into our platform, helping to reduce the manual work and compliance risk customers face from the FinCEN rule. Our goal is to empower our customers to confidently steer through this complexity and continue to provide the high-quality closing experience their clients expect.”

The FinCEN rule: timeline, requirements and pain points

The FinCEN Anti-Money Laundering (AML) Regulations for Residential Real Estate Transfers Rule requires professionals involved in real estate closings and settlements to report specific information for non-financed/cash transfers of residential real estate involving legal entities and trusts. 

In September, FinCEN postponed reporting requirements from December 1, 2025 to March 1, 2026. For transactions closing on or after that date, FinCEN will require reporting of detailed information on the transaction, including the beneficial owners or trustees of the purchasing entity and each payment made for the purchase of the property/transfer of the property. These requirements present substantial challenges for title & escrow companies including: 

  • Operational burden: Companies must develop and train their staff on new workflows and processes to identify and report transactions. This includes implementing new procedures to collect beneficial ownership information and completing the new Real Estate Report—a complex form with as many as 111 data fields. The entire process represents a significant change and additional workload.
  • Data security and delays: Collecting more sensitive personal data requires an increased level of security. At the same time, the closing timeline is put at risk if the necessary information isn’t collected promptly from all parties. 
  • Compliance risk: Failing to comply or submit complete reports comes with severe consequences. Title & escrow companies could face criminal and civil penalties, including a nearly $1,400 fine per violation and up to $108,489 for a pattern of negligent activity. Willful violations can result in up to five years in jail and a $250,000 criminal fine.

Qualia’s solution to alleviate FinCEN challenges

Qualia is proactively delivering an integrated solution directly within our cloud-based product suite to help title & escrow companies meet these compliance requirements. 

This solution enables title & escrow companies to flag reportable orders, collect all necessary information from transaction parties through the secure Qualia Connect portal, audit and report across all flagged orders to support the submission process, and track submission status. Within the Qualia platform, title & escrow companies can add tasks and automations supporting each step of the workflow, helping to ensure nothing is missed. Particular features include: 

  • Intelligent workflow automation: Use workflow automations to send information collection forms and assign key compliance tasks. 
  • FinCEN reportable order tracking: After reviewing transaction data to confirm if reporting is necessary, mark the order as “FinCEN Reportable,” enabling the order to be reported on and tracked through workflows and reports. 
  • Secure data collection with FinCEN Info Request: Use a highly secure and efficient method to collect required information from clients with an Information Request in both Qualia Core and Qualia Connect. This ensures that non-public information is not exchanged through a vulnerable channel like email.
  • FinCEN submission status tracking: FinCEN requires that all relevant transactions be reported within 30-60 days after closing. A dedicated view in Qualia Core displays all FinCEN reportable transactions, calculates their reporting due date, and displays the submission status for each order, serving as a compliance hub to ensure your reporting deadlines are met. Qualia is also committed to continuing to monitor FinCEN updates and scope the development of an integrated submission process directly from Qualia Core.

Conclusion

The FinCEN reporting rule is a substantial regulatory shift, but it does not have to become a disruptive operational crisis. 

By using Qualia’s new integrated features, title & escrow companies gain robust tracking, secure data collection via Qualia Connect, and powerful reporting and audit capabilities—advantages that help reduce the weight of the compliance lift through a more efficient and secure workflow. Qualia’s FinCEN solution empowers title & escrow companies to minimize manual work tied to the regulation and confidently meet its requirements.

To learn more about how Qualia empowers title & escrow businesses to operate efficiently and securely, speak to an expert today.

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