A transaction is considered non-financed when no mortgage or loan from an AML-regulated financial institution is involved at closing.

• If you are purchasing with financing from a traditional bank, credit union, or other AML lender, the transaction is generally not reportable.

• If you are purchasing with cash, private funds, hard money, seller financing, or financing that does not come from an AML-regulated lender, the transaction may be considered non-financed for reporting purposes.

Foothills Title reviews every file to determine whether reporting applies.

If a contract indicates financing but the lender has not yet been identified, our team may proactively begin gathering required information as though the transaction could be reportable. This approach helps prevent unnecessary delays between lender involvement and closing.

If AML-regulated financing is confirmed prior to closing, reporting is typically not required.

Our goal is simple: stay ahead of compliance requirements so your closing stays on schedule.

If You’re Purchasing Through a Trust

You may be asked to provide:

• Full trust name

• Trust formation date

• Revocable or irrevocable

• Trustee information

• Tax ID (if applicable)

• Government-issued ID for required individuals

In addition to trust details, federal reporting requires information regarding the source of funds used to complete the purchase.

Buyers may be asked to provide:

• Method of payment (wire, check, cashier’s check, etc.)

• Name of the financial institution sending funds

• Originating account details and, if necessary, documentation verifying the source of funds

• Amount of funds used for the transaction from each account

This requirement helps document how the purchase was funded when no AML-regulated lender is involved.

This information allows Foothills Title to complete federal reporting requirements when applicable.

If You’re Purchasing Through an LLC or Other Entity

You may be asked to provide:

• Legal entity name

• State of formation and formation date

• Tax Identification Number (EIN)

• Beneficial owner details (individual(s) with ≥ 25% ownership)

• Identification for individuals with substantial control

• Government-issued ID for required individuals

In addition to Entity / LCC details, federal reporting requires information regarding the source of funds used to complete the purchase.

Buyers may be asked to provide:

• Method of payment (wire, check, cashier’s check, etc.)

• Name of the financial institution sending funds

• Originating account details and, if necessary, documentation verifying the source of funds

• Amount of funds used for the transaction from each account

This requirement helps document how the purchase was funded when no AML-regulated lender is involved.

Foothills Title will explain exactly what is needed and how to provide it securely.

The FinCEN rule was issued by the U.S. Department of the Treasury to increase transparency around certain residential real estate transactions.

If a purchase meets the federal criteria, Foothills Title, as the settlement agent, must file a report that includes:

• Information about the property

• Purchase price and date

• Certain buyer details

• Limited seller information when required to complete the report

This requirement is federal law and applies nationwide.

Your privacy and data security are priorities.

Foothills Title:

• Collects information through secure online portals

• Uses encrypted systems and internal compliance safeguards

• Submits required information directly to FinCEN on your behalf

We collect only what is required by federal law.

Not when information is provided promptly. Early preparation helps avoid last-minute delays.

No. This is a federal reporting requirement, not an audit or inquiry.