Hi Escrow Pros,
Thank you for packing the house last night for our sold‑out Tri‑County Escrow Association meeting with Jennifer Felten, Esq. The content was outstanding—and mission‑critical for every California escrow desk.
Key takeaways you can use today
- Go‑live date: The FinCEN Final Rule takes effect December 1, 2025. All reportable closings on or after that date must comply.
- Nationwide, no dollar threshold: The rule applies across all counties and has no monetary minimum—if it’s a covered transaction, it must be reported.
- What’s covered: Non‑financed (all‑cash) transfers of 1–4 unit residential, condos, and co‑ops to entities or trusts, with beneficial owner information required.
- Who files (the “cascade”): Primary responsibility starts with the closing/settlement agent named on the settlement statement, then moves down the chain if not applicable.
- Verification standard: You’re not required to investigate, but you cannot ignore information you know or believe is incorrect. Document your file.
- Record retention: Keep the Real Estate Report, supporting ID/ownership docs, and proof of submission for at least 5 years.
- Timing pressure: Expect a 30–60 day reporting window—build your workflow now to avoid late filings.
Action items for escrow teams
- Map your internal “who files” workflow and backups (align with the cascade).
- Update intake checklists for entity/trust buyers and beneficial owner docs.
- Set retention rules and proof‑of‑submission procedures (5‑year minimum).
- Train staff on “trust but verify” (don’t ignore obvious inaccuracies).
Big thanks to our Dinner Sponsor: Eric Spitz, MY NHD—we appreciate your support of the escrow community!
Next TCEA Dinner Meeting
Date/Time: Monday, September 9, 6:00 PM
Location: Old Spaghetti Factory – Rancho Cucamonga
Seats go fast—invite your escrow teammates and register now.
👉 [Register for Sept 9 Meeting]
(If you need the link, reply to this email and we’ll send it right over.)
Questions from the session? Reply here or DM us—we’ll get you answers and resources for your team.
See you September 9!
—Tri‑County Escrow Association Leadership
P.S. If you missed the handout highlights, reply and we’ll share the slide references on effective date, scope, and filing responsibilities.