As a follow-up to the issues discussed during the UTA-led coalition meeting with FinCen on January 30th, UTA submitted a supplemental letter to further support full exemption or further extension of the effective date of March 1, 2026, for non-judicial foreclosures from the Real Estate Reporting Rule. Along with the letter, UTA provided FinCen with data demonstrating that non-judicial foreclosures are a very small percentage of all real property sales in non-judicial states and that of this small percentage, an even smaller percentage involve transfers to entities that are not exempt.

UTA’s President Edward Treder and UTA’s Corporate Counsel, Michelle Mierzwa, had met for 40 minutes via Zoom on January 30th, with six members of the Treasury Department’s FinCEN staff.

The supplemental letter followed an initial letter drafted by UTA Corporate Counsel and Legislative Co-Chair Michelle Mierzwa, and signed by MBA, CalMBA, CMA, USFN, ALFN, NADP, CRAN and WFG that explained the significant adverse impact on nonjudicial foreclosure trustees and firms of the new Real Estate Reporting Rule applicable to non-financed real property transfers to entities. The letter requested an extension of the March 1, 2026 effective date.

Read the supplemental letter here.