As many of you know, there’s a new federal reporting requirement going into effect on March 1st under the Financial Crimes Enforcement Network (FinCEN). I want to make sure you’re fully informed about how this will impact certain transactions — especially all-cash deals.
What This Means for All-Cash Buyers
Beginning March 1st, certain all-cash transactions will require additional reporting to comply with the new government mandate. When a transaction falls under this rule, there will be additional administrative fees associated with collecting, verifying, and submitting the required information.
This does not apply to every transaction — only those that meet the reporting criteria — which is why you may see this fee appear on some closing statements but not others.
Frequently Asked Questions
1. Will this fee be included in the standard closing or settlement fee?
No.
The Department of Financial Services has clarified that the FinCEN reporting fee cannot be bundled into the standard closing or settlement fee, since not every transaction is subject to this rule.
For transparency — and for accurate comparison shopping — the regular settlement or closing fee must reflect only the standard services that apply to all transactions. If a deal requires FinCEN reporting, it will appear as a separate line item on the settlement statement.
2. Can the reporting fee vary?
Yes, it can — particularly if a third-party vendor is used to handle the compliance process.
If a title company or settlement agent works with a third-party provider to collect and manage the required 111 data fields, the cost may be passed along to the buyer. However:
The fee must be properly disclosed.
The charge must reflect actual work performed.
The settlement statement should clearly show who is being paid.
For example:
FinCEN administrative charges – Vendor $120 / Settlement Agent $5 – Total: $125 (Buyer)
Full transparency is key.
3. Why would there be a vendor fee at all?
Some underwriters may offer submission of the form at no cost. However, it’s important to understand what that actually includes.
Ask:
Who is collecting all 111 required data points?
Who is contacting the parties to gather missing information?
Is the data being transferred securely?
Who is tracking compliance before closing?
If the title company’s staff is gathering all the information, completing the form, following up for missing details, and simply sending it to the underwriter — then yes, submission may be free because the office is doing the work.
Third-party vendors, on the other hand:
Collect the required information through secure platforms
Track missing fields
Send reminders before closing
Reduce compliance risk
For many, the added cost provides peace of mind and minimizes the risk of delayed closings.
Bottom Line for Buyers and Sellers
If you’re purchasing property with cash after March 1st, be prepared for the possibility of an additional compliance fee if your transaction meets the reporting requirements.
Not every deal will be affected — but for those that are, the cost reflects the administrative and compliance work required under federal law.
If you have questions about how this may impact your specific purchase or upcoming closing, I’m happy to walk you through it and help you understand what to expect.
As always, my goal is to make sure you’re informed, prepared, and confident every step of the way.