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FinCEN's residential mortgage lenders and originators in 2026: BSA obligations, the RRE Rule, and the path forward after Flowers Title

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FinCEN's residential mortgage lenders and originators in 2026: BSA obligations, the RRE Rule, and the path forward after Flowers Title

Non-bank residential mortgage lenders and originators have been subject to FinCEN AML rules since August 13, 2012. The 2026 Residential Real Estate Rule took effect March 1, 2026 and was vacated by a federal court on March 19, 2026. The 2012 RMLO obligations are unaffected. Here's the complete picture for non-bank residential mortgage lenders and originators in 2026.

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