24 Hour Closing Anti-Money Laundering Information Collection & Certification – Buyers
  • 24 Hour Closing Anti-Money Laundering Information Collection & Certification – Buyers

    Required information for real estate transactions involving entities or trusts, pursuant to FinCEN Real Estate Report Rule 31 CFR 1031.320.
  • BACKGROUND:

    This is a new, federal law effective March 1, 2026. We admit it's crazy and hate it as much as you do. But it's up to a $250,000 fine if closing attorneys do not demand that you fill this form out. It is not optional.


    If the Buyer is an LLC or entity that is 'cash' or using a lender that doesn't have anti-money laundering protocol (hard money lender, credit unions, parents/family), this form becomes mandatory and cannot be avoided unless you change the purchase to purchase in your personal name. You could later quitclaim to a trust as part of 'estate planning' which is an exemption from this form but transferring to an LLC would again trigger this form.


    Your closing has been determined to be a type of closing where this information is required by the federal government prior to closing. Up to a $250,000 fine may be levied against the lawyer doing the closing if this information is not collected in advance of closing. The government says that this law was created to stop money laundering from criminals and child trafficking, but appears that this law was
    actually created to help the IRS track you and your bank accounts and income/assets.


    This form requests information necessary to meet the reporting requirements. For more information about FinCEN's Real Estate Report and what transactions are covered go to alta.org/fincen. The only way to avoid this is to buy the property in your personal name or use a lender that has money laundering protocols in place (big banks like Wells Fargo)

  • TRANSFEREE ENTITIES AND TRUSTS

  • The regulation applies to purchases by:
    Any entity - the only exemptions are transfers to an entity pursuant to divorce, court order or will/death of person

  • Property & Transaction Details

    Please provide details about the property and transaction.
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  • Settlement Agent/Reporting Person:

    Pinyan Law Office PLLC dba 24 Hour Closing

  • Part 1: Information About the Person Completing This Form

    Provide your information as the person completing this form.
  • Part 2: Reporting Exemptions for LLCs, Corporations, and Trusts

    Indicate if any exemptions apply to this transaction.
  • Part 3(a): Transferee Entity Information

    Provide information about the entity acquiring the property.
  • TRANSFEREE ENTITY INFORMATION REQUIRED

  • The Following pages of information about the transferee (Buyer) entity and associated persons is required by the Federal Government.
    The Feds require reporting of EACH beneficial owner of the transferee entity. A beneficial owner is someone who


    (i) exercises substantial control over the transferee entity, or
    (ii) owns or controls at least 25% of the transferee entity's ownership interests.


    This includes: full legal name, date of birth, complete current residential street address, citizenship and IRS taxpayer identification number if available (if not available other identifying information is required). "substantial control" means any corporate officer (CEO, FCO, COO) or person who has authority to make important decisions

  • Part 3(b): Transferee Trust Information

    Provide information about the trust acquiring the property.
  • TRANSFEREE TRUST INFORMATION REQUIRED

  • Trust info including its legal name, date trust instrument executed, IRS taxpayer identification number if available (if not available other identifying information is required) and whether trust is revocable.


    It also requires reporting of EACH beneficial owner of a transferee trust which includes (i) the trustee, (ii) a beneficiary of the trust who has the right to demand a distribution of, or withdraw, substantially all of the assets of the transferee trust, and (iii) a grantor or settlor who has the right to revoke the transferee trust. See Part 3(b) of this collection form for a complete list of who are beneficial owners of a transferee trust.

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  • Part 4: Funds Used for Acquisition of the Property

    List all accounts and funds used for the property acquisition.
  • Part 5: Certification

    Please review, certify, and sign below.
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