Attention Missouri Real Estate Investors
UPDATE March 25, 2026: Due to a court ruling, this is temporarily paused. Title companies are no longer required to collect this information. This will very likely continue to shift and change as it goes through the court system but as of now, there’s no need to submit any paperwork for FinCEN AML requirements.
On our recent Buyers Club Live call, Kim Kramer (VP of Escrow Operations at True Title) broke down a major federal change that will impact a lot of Missouri investors who buy in LLCs/trusts using hard money, private money, or cash.
This isn’t a “True Title thing.” It’s a FinCEN thing and it applies nationwide.
FinCEN (the Financial Crimes Enforcement Network) created this new reporting requirement to reduce money laundering through residential real estate, especially purchases made through entities where the “real owner” is harder to identify.
The effective date
The reporting requirement applies to deals that close on or after March 1, 2026.
The 3 triggers (when a deal becomes “reportable”)
A transfer generally becomes reportable when all three of these are true:
1) It’s residential real estate
This includes:
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1–4 unit residential properties
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condos / co-ops
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vacant land zoned for residential use
2) It’s “non-financed” (not bank financing subject to AML rules)
Think of this as:
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cash
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hard money
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private money
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gifts (family funds, partner funds, etc.)
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some credit unions / lenders that are not covered under the relevant AML framework (your title company will help verify this)
3) The buyer (transferee) is an entity or trust
This rule targets transfers to:
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LLCs
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corporations
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partnerships / similar entities
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trusts
Big clarity point from the call:
If the buyer is an individual (personal name), this rule typically does not apply, even if the seller is an LLC/trust. The buyer is what triggers this rule.
Who has to file the report? (Not you.)
In most cases, the reporting obligation lands on the settlement/title side, often the settlement agent, title agent, escrow agent, or attorney using a defined “reporting cascade.”
So, investors and agents aren’t the ones filing the report, but you will be asked for the info needed to complete it.
What information will be collected (short version)
If you buy in an LLC or entity
You’ll provide:
Legal entity info (name, EIN, address – no PO boxes)
The real people behind the entity (owners and control persons)
Rule of thumb:
Anyone who owns 25%+ or controls decisions must be disclosed.
If your LLC owns another LLC, FinCEN follows the chain to the real humans.
If you buy in a trust
You’ll provide:
Trust details
People connected to the trust (trustees, grantors, and some beneficiaries)
Yes — this can include family members listed in the trust.
Seller info may also be required
If the buyer triggers the rule, the seller must provide basic tax-style info
(name, address, and tax ID — similar to a W-9).
This can add friction in Missouri deals with:
estates
trusts
older sellers
assignments
Can I avoid this by buying personally and deeding to my LLC later?
Don’t assume that avoids reporting.
A later transfer into an LLC or trust can still be reportable.
Your title company should flag this early.
Will this delay closings?
Only if the info isn’t ready.
Most title companies will treat missing information as a closing blocker because they carry the compliance risk.
Missouri investor reality:
If you like fast closings, have your entity or trust info ready before you go under contract.
Will there be a fee?
Yes.
Most title companies will add a compliance fee.
The exact amount will vary by company.
Common exemptions (high level)
Some transfers are exempt, including:
transfers due to death
certain divorce-related transfers
transfers involving regulated entities (banks, public companies)
some court or bankruptcy transfers
Why FinCEN is doing this (plain English)
FinCEN has already been tracking high-risk, all-cash and entity purchases for years.
They’re expanding that effort nationwide because entity-based, non-bank purchases are higher risk for financial crime.
What Missouri investors should do now
1. Clean up your entities
Fix stacked LLCs, outdated operating agreements, and unclear ownership.
2. Keep a closing-ready folder
entity docs (OA + EIN letter)
ownership list (25%+ owners and control persons)
current addresses (no PO boxes)
trust certification and people list (if applicable)
3. Tell your title company early how you’re funding the deal
Last-minute switches to private or hard money create problems.
4. Wholesalers: don’t collect SSNs or sensitive seller info
That creates liability for you.
