All,
An attorney friend on another list reminded me of several exemptions that I hadn't thought about, where the sale doesn't have to be reported. When the entity is:
A publicly traded company
A church or other non-profit
An insurance company
A bank or other financial institution, plus several others
There are 23 total, but she specifically wanted to mention "publicly traded company" because a lot of the big home builders are, in fact, publicly traded, so they'd be exempt from land purchases. The publicly traded national homebuilders in 2026 include D.R. Horton (DHI), Lennar (LEN), PulteGroup (PHM), Toll Brothers (TOL), and NVR (NVR). These companies dominate the market, with D.R. Horton as the largest, followed closely by Lennar and PulteGroup. Other significant public builders include Meritage Homes, KB Home, and Taylor Morrison.
Here are the full 23 exempted companies from the FinCEN site:
The following table summarizes the 23 exemptions:
Exemption No. Exemption Short Title
1 Securities reporting issuer
2 Governmental authority
3 Bank
4 Credit union
5 Depository institution holding company
6 Money services business
7 Broker or dealer in securities
8 Securities exchange or clearing agency
9 Other Exchange Act registered entity
10 Investment company or investment adviser
11 Venture capital fund adviser
12 Insurance company
13 State-licensed insurance producer
14 Commodity Exchange Act registered entity
15 Accounting firm
16 Public utility
17 Financial market utility
18 Pooled investment vehicle
19 Tax-exempt entity
20 Entity assisting a tax-exempt entity
21 Large operating company
22 Subsidiary of certain exempt entities
23 Inactive entity
However, the FinCEN site was careful to point out that just because the parent company is exempt, doesn't mean a subsidiary or d/b/a is also exempt. Be cautious as you move forward!
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Cathy Clamp CTIP
Escrow Officer
Heart of Texas Title Co., LLC
Brady TX
+1 (325) 597-0796
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Original Message:
Sent: 02-24-2026 17:22
From: Cathy Clamp
Subject: New FinCEN RRE rule
Pamela,
I did create one for our files. I'll send it to you off-line.
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Cathy Clamp CTIP
Escrow Officer
Heart of Texas Title Co., LLC
Brady TX
+1 (325) 597-0796
Original Message:
Sent: 02-23-2026 12:36
From: Thomas Goff
Subject: New FinCEN RRE rule
Has anyone created a file checklist that they would be willing to share to determine if the deed is FinCIN eligible?
-- -Have a blessed day!
Pamela S. Willis
Goff & Goff PSC
Attorneys at Law
53 Public Square
Leitchfield KY 42754
P: (270) 259-9237
F: (270) 259-0060
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