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  • 1.  Evaluating Rate Filings to Offset FinCEN AML Compliance Costs

    Posted 07-17-2025 15:29

    As we prepare for the December 1, 2025, implementation of FinCEN's new anti-money laundering (AML) reporting requirements, our operation is assessing the financial and operational impact of compliance-particularly the burden of filing Real Estate Reports for non-financed residential transactions involving legal entities or trusts.

     

    We are considering whether to file a rate with our state insurance division to help offset these new obligations. I'm reaching out to see if others in the industry are exploring similar strategies.

     

    One of the challenges we're facing is how to accurately calculate the cost of compliance to be passed on to consumers. While FinCEN has provided time burden estimates-generally in the range of 20 to 40 minutes per report-we're finding these may not fully capture the real-world effort required, especially when factoring in training, data collection, internal reviews, and system integration.

     

    I'd be very interested to hear how others are approaching this. Are you conducting internal time studies, relying on vendor input, or using another method to estimate the cost per transaction? Have you found the federal estimates to be a helpful starting point, or are they proving too optimistic for practical planning?

     

    Thank you,

     

    Annette Young

    Heritage Title Company

    Denver, Colorado

    970-254-4063

     

     

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  • 2.  RE: Evaluating Rate Filings to Offset FinCEN AML Compliance Costs

    Posted 08-06-2025 11:04

    Hi Annette, 

    We’re seeing a lot of the same challenges—and you’re absolutely right that FinCEN’s time estimates don’t reflect the full picture. Their 20–40 minute range doesn’t account for collecting extra info from buyers/sellers, answering questions throughout the transaction, or getting additional documents signed. Plus, agencies in states like PA (with all-inclusive filed rates) are pretty limited in how they can recoup any of those costs.

    I covered all of this (and more) in a recent Q&A roundup article for the Wicked Title Forum, including ideas I’ve heard from other agencies about how they’re approaching cost recovery, outsourcing, and other concerns. If you're in the trenches trying to figure this out, I think you'll find it useful:

    🧠 You Asked, We Answered: ‘3 Hours Per Report?!’ and Other FinCEN Fears—Debunked
    👉 Read the full article

    Hope it helps!



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    Publication & Online Business Support Community for the Title Industry
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