FinCEN Real Estate Reporting Rule
What It Means for Trust Transfers
Beginning March 1, 2026, new federal reporting requirements issued by the Financial Crimes Enforcement Network (FinCEN) apply to certain real estate transfers involving trusts and legal entities.
If you are transferring timeshare or vacation ownership inventory into a trust or Entity, additional reporting obligations may now apply.
Vacation Ownership Services Title Agency (VOSTA) is prepared to assist with compliance.
Why This Rule Exists
FinCEN’s Real Estate Reporting Rule was created to:
- Increase transparency in real estate ownership
- Prevent money laundering through trust and entity structures
- Identify beneficial owners behind legal entities
- Strengthen federal oversight of non-financed property transfers
Historically, many transfers into trusts did not require federal reporting. That changes in 2026.
Does This Apply to You?
You may be subject to reporting if:
- Ownershipis being transferred into a revocable or irrevocable trust
- The Transferee is a legal entity
- There is no traditional bank financing involved
- The transfer meets FinCEN’s reporting thresholds
We evaluate each file individually to determine whether reporting is required.
What Information Is Required
To complete a FinCEN filing, we must collect and verify:
For Individual Owners
- Full legal name
- Date of birth
- Current residential address
- Identification number (Driver’s License or Passport)
- Issuing state or country
For Trusts
- Full legal trust name
- Date trust was established
- Trustee information
- Beneficial owner information
- Trust documentation confirming authority
For Corporate Trustees (if applicable)
- Legal entity name
- Business address
- EIN
- Controlling individuals
- Ownership percentages
Incomplete or inaccurate information may delay your transfer.
Is There a Government Filing Fee?
No.
FinCEN does not charge a fee to submit the report.
However, the reporting professional must:
• Collect and verify required documentation
• Analyze trust and ownership structures
• Prepare the electronic report
• Submit within the required timeframe
• Maintain internal compliance records
This typically requires 30–45 minutes per file, and more for layered trust structures.
VOSTA FINCEN Compliance Fee
Standard Trust Transfer Filing: $175
This fee reflects the time required to properly review, prepare, and submit the required federal reporting.
Documents Required From You
To begin the process, please provide:
• Copy of the complete Trust (or Certificate of Trust)
• Government-issued photo ID for all required individuals
• Current mailing address confirmation
• Completed FinCEN Information Worksheet (included in your opening package)
Why Work With VOSTA?
• Licensed title agency
• Experienced with multi-party and trust transfers
• Familiar with federal compliance requirements
• Structured intake process to prevent delays
• Transparent, flat-fee pricing
We do not cut corners on compliance.