Episode Transcript
[00:00:00] Foreign.
[00:00:06] To go over the FinCEN residential real estate Reporting rule voiding by the Eastern District of Texas.
[00:00:19] So as you may recall if you read my newsletters, if you've kept up with our YouTube channel, you have seen me often write about the FinCEN real estate reporting Residential Real estate reporting rule that was coming out. Started writing about it almost two years ago in our weekly newsletter. If you have not subscribed to that, I would recommend that you subscribe to it. Especially if you're a real estate investor or an entrepreneur real estate professional in any way, form or fashion, not just in Florida, but anywhere in the United States.
[00:00:51] And also of course, keep up with our channel. Subscribe to this channel so you can also keep up with what's going on in real estate legal world and business legal world as things happen.
[00:01:02] Gonna apologize for how I'm dressed down. Very casual. It's a Saturday. The ruling came down on Thursday and it just started trickling out into the real estate title news world on Thursday.
[00:01:16] I heard about the order coming down out of the Eastern District of Texas on Friday. Wrote about it Friday night, put out an alert newsletter Friday night on March 20. The ruling came down on March 19, 2026. I wrote about it and now I want to record a video.
[00:01:34] Here I am on March 21st recording the video about what this means for real estate professionals and they're involved. First, let's talk about the rule and what it meant in the first place. So the rule came out of the Corporate Transparency Act. That's very important.
[00:01:51] That act was passed in President Trump's first term back in 2016-2020, when he was the president. Back then, he actually vetoed the Corporate Transparency Act. It was part of the National Defense Authorization act at the time. It had been stuck into that law and Trump at that point completely vetoed it. He has made 12 vetoes over the two terms that he served as president and only one veto was ever overridden. And it was that National Defense Authorization act, which included the Corporate Trans Transparency Act. So that is the only time Congress has ever overridden a veto by President Trump in either of his two terms as president. So as you can probably guess, there is no love lost for this act, this law, in the, in this administration, in this executive branch. They really don't appear to like it, don't really want to enforce it as part of the Corporate Transparency Act. Some of you may remember that there was the business beneficial ownership interest reporting that was required. FinCEN made a rule that went into effect under the Biden administration and in between. And under that rule, everyone who had an LLC or corporation, any other type of entity inside the United States, they were supposed to go in and register who the true human beneficial owners and controllers of those entities were. All over the country. There was something like 60 million, 80 million different entities that were going to have to register.
[00:03:18] So that was delayed, delayed, delayed. And finally it was, it was challenged in the courts in many different districts around the country. And the courts were coming up with conflicting decisions as to whether it was constitutional or not, whether it was enforceable or not, whether it violated the Administrative Procedures act or not as it was promulgated.
[00:03:38] So lots and lots of court cases about that, but ultimately it came up to the Supreme Court. Supreme Court said, enforce it or don't. But procedurally the court cases have been heard in a way that we're okay with it, with the law proceeding as planned. But if you don't want to enforce it, don't. So the Trump administration, his Secretary of Treasury, at that point, they said, look, we've delayed this thing. Nobody's complying with it completely. It's very difficult to comply with. It's taken a lot of time. It's requiring a lot of people, a lot of people, effort and energy and money across the country to comply with it. So tell you what, we're just not going to enforce that law, the beneficial ownership interest Reporting under the FinCEN, under the Corporate Transparency act, we're not going to enforce that rule against US Based companies.
[00:04:31] So, but if you're a foreign based company, you still have to report who the beneficial owners are of the company. So what do they do? They just form a US llc.
[00:04:39] It may be owned by a foreign entity, but that does not mean you have to report it because you're not actually in the United States doing business. You're in the United States doing business under your U.S. entity. You just happen to be a shell company for the foreign company, which is the whole reason that the Corporate Transparency act was passed.
[00:04:57] Which brings me back to the next point. The Corporate Transparency act was intended to help combat money laundering and human trafficking and drug trafficking and arms trafficking from around the world. The United States has the most stable and trustworthy, one of the most stable and trustworthy financial systems in the, in the world.
[00:05:16] So it is known that criminals from around the world, they take their money that they make off of their illegal activities. And a lot of times they move it into the United States, into our banking system, into our financial system, to protect it, to launder it. So Whether they got it from human trafficking or drug trafficking, whatever they've done, they will move that money into the United States and they will protect the money. They will wash it. A lot of times they launder that money through real estate.
[00:05:45] So that brings me to the second part of the Residential Real Estate Reporting Rule that FinCEN also promulgated. After a couple of years of commentary and rulemaking procedures that they would normally go through under the Corporate Transparency act, Congress authorized FinCEN to do what it takes to find suspicious activities with money in the United States. Now, if anybody ever knows you've got a rule, and I've talked about this in an earlier video, we'll put a link to it down below.
[00:06:17] If you are laundering money or if you're doing something that looks suspicious, of course banks are always going to report that on a suspicious activities report form to FinCEN immediately to let them know, hey, this is going on and there are certain things that are automatically deemed to be suspicious. If you are depositing $10,000 or more in cash in a bank account, for instance, that's a suspicious activity. And they're going to file a report and let FinCEN know, hey, this guy's putting $10,000 in cash in a bank account. And that looks odd to us.
[00:06:49] So they wanted to, they, they, they realized that sometimes criminals were using residential real estate. Of course they also use commercial real estate. But for whatever reason, they focused on residential real estate to launder the money from their criminal activities inside the United States.
[00:07:06] So they came up with this idea that, hey, we'll pass a rule that if anybody is buying residential real estate, regardless of how much they're paying for it, or if they're really not paying anything at all, if it's just a transaction and there is no bank involved or there's no mortgage lender involved who has to comply with the anti money laundering rules that are already in place, we are going to require the title companies or lawyers who are involved in that transaction to report it because it will automatically also be deemed to be a suspicious activity. So FinCEN basically came down and said, hey, if you are buying residential real estate and you are not going to a bank or a licensed mortgage lender loan originator to borrow the money to buy that real estate, that's suspicious activity. Therefore, anywhere in the United States for any amount of money or no money at all, we will require you to file this report. And in that, so long as you're buying it into an entity or a trust, this is something they'd never done before and it was, I think it was going to affect a lot more closings, a lot more transactions than they estimated. Based on our experience. We work with a lot of real estate investors who buy properties subject to they buy them with solar financing, they buy them with private or hard money loans. Those are all non finance transactions as far as FinCEN is concerned because most of our clients also buy their properties into LLCs or especially land trusts. They use land trust. So a trust and a transaction, a non finance transaction for residential real estate is going to be suspicious according to FinCEN.
[00:08:45] So they would have to comply with this rule. Now, complying with the rule, I've gone over this before, means that the title company, the lawyers, whoever it is, who is in charge of recording the deed, whoever's in charge of dispersing the funds, whatever they are liable, they are responsible for collecting the human names, home addresses, dates of birth and Social Security numbers of every single human being involved in that transaction. Who controls the money, who funded the deal. If it's a private lender, you're going to get all their information, the trustees people, the trustee themselves. If it's a trust, not only that but also the person who is signing. So in our case we have entities that act as trustee. So the actual human being who is executing the documents for the closing would have to disclose their name, home address, date of birth and Social Security number to all these title companies. And now that has to then get gathered up also the buyers and sellers, of course. So if it's going into a trust that's going into an LL that is held by an LLC and then that is held by another LLC that is owned by humans, ultimately you're going to get down to those human beings and you're going to report their name, home address, Social Security number and their dates, birth to FinCEN. And it goes into the Bank Secrecy act database, all that information goes in and the title company or the law firm handling the closing or handling the recording of the deed, or preparing the deed, whatever they may be doing in that, has the duty, the obligation, the legal requirement that they have to collect this information and report it. If they cannot collect the information and report it, then they simply must deny and not do the closing.
[00:10:18] Well, we've been doing this since March 1st, it went into effect on March 1st and I tell you, it's been a lot of work on our end as the trustee. We are getting requests from title companies to go online and fill out forms online that require two factor authentication with text back, two factor authentication to Log into these websites to enter the data to collect the data. It's adding probably easily an hour to two hours to every single closing where we are signing as the buyer to buy the property as trustee of a trust because they are buying the property into a trust and they are usually not financing it with a bank or a licensed mortgage lender that would have to, who would have to comply with the anti money laundering rules that are out there because they're banks. So it's really had a lot of time. We have developed forms that we filled out. We've had meeting after meeting. We've had discussions internally on business processes.
[00:11:18] We have forms that we have gotten from Alta, we have forms we've gotten from different underwriters, title underwriters that we fill out. Every form is different online, every form is different. The two factor authentication is pretty much impossible for us to do because to do that you have to put in your personal cell phone number. And our employees just don't want to be putting in their personal cell phone number to do this because what happens if they're out one day and then someone else has to go in and update the information or complete the information that they've started entering into this form? Now they're on vacation or they're sick. We've got to track them down, say, hey, you should have gotten a code. Well, yeah, I got a code two hours ago. Well, that code's expired. Well, now give me a new code. Okay, well I'm going to send it again. Well, the code didn't come through. We can't do that. That just does not work for us. So we just said, fine, we're going to fill out a form, our forms, no matter what it is, we'll send to the title company. Title companies got to fill it out. Title companies have said, look, everybody's dumping all this work back on us to collect this information, enter this information, we're on the hook if we don't do it right. We're on the hook for fines and potential prison if we don't do it correctly. So we are going to charge more. So the cost of closings have already gone up across the board. We raised our price for closings as well because we had to do something to help cover our extra time and labor it's going to take to get these closings across the board. Finish line. As a buyer inside of a trust, our clients who use LLCs to buy properties, they are pulling their hair out because they have to do this with every single closing. So if you're a fix and flipper or a renovator or a construction company that buys lots of houses, renovates them and sells them during the year their residential properties purchased into an entity. At that point, you have to provide all this information over and over to all these different title companies, depending on who the seller has chosen. And everybody's got their own way of doing it and it's just a mess. So in essence, it has really created a massive speed bump and expense bump to getting your closings done across the country, not just in Florida. This is not just in Florida, folks. This is across the United States because it's any U.S. property, any U.S. residential property being sold. Now, this has typically been done in targeted geographic areas around the country.
[00:13:36] The fence end for years has had geographic targeting orders where in certain areas, if someone is buying a property without financing and it is in a certain geographic area and it is over a certain purchase price, that gets reported to FinCEN as well. That's been done for years and that's really been no problem. That that includes individuals, entities, trusts, whoever it may be. You have to report this information to FinCEN. That's been done for years. It did not affect every single residential cash transaction. It only affected a certain few. Like in Miami, sometimes it was a million dollars and up. In Orlando, it may have been $300,000 and up. It just depended on the area. And they changed it up about every quarter. They would change up the locations just to sort of keep people on their heels, keep the crooks on their heels as to where they were going to buy property. Whether it's Houston, New York, Philadelphia, somewhere on California, somewhere in Florida, somewhere in Illinois. They would keep them sort of in the dark as to where these geographic targeting areas were going to be. So that seemed to work out, but then FinCEN said, no, no, no, now we're going to make that, but we're going to make it go nationwide on every single real estate cash transaction for a residential property.
[00:14:50] So we come down, we have a case that's filed Fidelity National Title filed a case and sued the Secretary of Treasury, Scott Besant, in the federal District Court in Orlando actually a year or so ago over this law saying it was unconstitutional. They were fighting it on constitutionality and some other issues, some other counts. But that really went to the core that, hey, this is unconstitutional. You're turning every single title agent, every single lawyer who touches a deed and records a deed going into a trust or an entity with potential liability if it's, if, if it is a reportable transaction and they don't report it or they don't report it properly. So you are turning everyone into a law enforcement officer. And, and that's not fair. That's not right. We shouldn't do that to people.
[00:15:41] Well, that case lost. I mean, it went through summary judgment. And the magistrate judge in Orlando recommended to heard arguments, read all the briefs, researched the law, and recommended to the district judge, district court judge that they enter the order granting FinCEN, Secretary of Treasuries, Secretary of Treasury's motion to dismiss the case, motion for summary judgment, saying, no, no, no, it is constitutional, it's perfectly fine, the law is perfectly fine. And that's what happened in Orlando. So in Orlando, the federal district court said the law is completely enforceable, nothing wrong with it. Well, parallel to that and actually prior to that, or actually may have been a little bit after. But anyway, at some point around the same time, another case was filed by Flowers Title companies against the Secretary of Treasury in the Eastern District of Texas in the Tyler Division. That's near Houston.
[00:16:37] So they did the same, they did the same thing, but their case was more premised on saying that FinCEN had violated the Administrative Procedures act in promulgating this rule, basically saying that FinCEN exceeded the authority Congress had given it to enforce the Corporate Transparency Act.
[00:17:00] So in that case, Flowers Title was arguing, you know, the law may be constitutional. We don't know, it doesn't matter.
[00:17:09] It's more statutory based that there's an Administrative Procedures act that spells out exactly what all the different agencies are allowed to do in implementing laws and enforcing laws that Congress passes.
[00:17:27] And that's the Administrative Procedures Act. Now this was interesting because the court came down and said, yes, FinCEN completely violated the Administrative Procedures Act. They went too far.
[00:17:41] They're basically trying to fit an elephant into a mouse hole here that the Congress was more, you know, said, hey, you've got to report suspicious activities. And FinCEN has just unilaterally, without a good faith basis, said that every single residential cash closing in the United States into a trust or an entity is automatically a suspicious transaction.
[00:18:07] And that doesn't fly with the court. The court thinks that's, that's just overreaching. So they said under the law, violates the Administrative Procedures Act. As such, it is vacated. So the rule is completely vacated. The real estate, the residential real estate reporting rule is vacated nation. So because it's been vacated nationwide, that court found that it's no good nationwide and therefore no one should have to comply with this rule because it is an illegal rule under the Administrative Procedures act because FinCEN exceeded Congress's statutory authority that was given to them to enforce the Corporate Transparency Act. That's the basis of this order out of the Eastern District of Texas.
[00:18:53] Now, some of you may remember I talked about a case, I think last year, the US Supreme Court. Now, the US Supreme Court came down and said, look, look, look, these district courts, these trial court judges all over the country cannot be entering injunctive relief. They can't be passing injunctions, entering injunctions that are nationwide. They don't have that authority.
[00:19:18] But the court was also very clear to carve out and say, but we're not talking about something that may be illegal under the Administrative Procedures Act.
[00:19:30] So if a court finds something's illegal under the Administrative Procedures act, that issue is not before us. That's going to have to come back to us. Because the Supreme Court never. And no court in the United States ever gives an advisory opinion.
[00:19:44] There are other countries where the like. In Portugal, Congress, their, their Congress, their parliament, will pass a law. One of the things that that law has to do is it has to go to the court and the court, the top court in the land and the top court in the land has to review that law and determine whether it's constitutional or not before it goes into effect. And if the court says it's okay, then it goes to the president, the president signs it or vetoes it, and then it goes back to the parliament to put it in place or not let it die.
[00:20:14] The United States has never done that and never will do that. Our courts do not issue advisory opinions. So the case that was before them a year or so ago did not bring up the Administrative Procedures act fecature, the vacating a law under the Administrative Procedures Act.
[00:20:33] And because of that, it wasn't before them. So they said, hey, we're just being clear here. We are not talking about anything that comes before the courts based on that.
[00:20:42] So Flowers, their lawyers are pretty smart to say, hey, let's bring this under. Let's bring our cause of action to challenge this rule under the Administrative Procedures act, saying they violate that. Because the Supreme Court has said, we're specifically, we've not made a decision about that yet. So if a court, if a district court says that a law is, has been a rule, has been illegally promulgated, created under the Administrative Procedures act, and that district court, that trial court judge, finds that as a matter of law, then it'll have to come back to us, to the Supreme Court to determine whether that is nationwide, or whether it only applies to that district.
[00:21:25] So nobody really knows.
[00:21:26] But this judge has passed it saying, well, the law is invalid, therefore nationwide. If the law is invalid in eastern Texas, Eastern district of Texas, it has to be invalid nationwide.
[00:21:38] He did not enter an injunctive relief. He said the law was invalid and therefore unenforceable. The rule, the rule was unlawful and therefore unenforceable.
[00:21:49] So with that said, everybody's come back to me ever since I put out that alert on Friday the 20th, that evening. And everybody said, okay, so what does this mean? Does this mean title agents have written me and said, so does mean, does this mean I stopped collecting the information Buyers have written me who are buying into trust or buying into LLCs. Hey, I've got to close in next week. Does this mean that I still have to provide all this information to the title company or not?
[00:22:20] Well, we're up in the air. So any, any order entered by a trial court judge is appealable.
[00:22:28] They can, the other side can make a motion to stay.
[00:22:33] Well, first they'll make a motion to reconsider. Hey, judge, you know, look at this again, please reconsider. And the judge is going to go, yeah, I looked at it, it's fine. Of course they're, they're not going to reconsider it. They may go, okay, well, fine, Judge, at least stay your order while we appeal it. A lot of times the judge goes, no, I'm not going to stay it while I appeal it. You're going to have to ask the court, the appeals court, to stay my order while you appeal it. So at that point, then they appeal, they file a notice of appeal with the court of appeals, the court of appeals. I know in the fifth Circuit Court of appeals and most courts of appeal, they have a procedures panel. So it may be three judges out of that nine judge panel in that circuit court of appeals. So those three judges will, as a procedural matter, look at it. This is exactly what happened with the Beneficial Ownership Interest Reporting act rule.
[00:23:25] And the procedures panel may say, yes, it is stayed. So everything's on hold. So as. So whenever the, the court says that order is stayed, then that means the rule is still in effect. So it just keeps on going as normal as it's going right now. You have to keep collecting the information. You have to keep reporting the information.
[00:23:46] What happened with the BOI reporting is they appealed internally inside the fifth District Court of Appeal.
[00:23:54] Actually, they didn't even appeal.
[00:23:56] The court of appeals took it on themselves to convene the entire nine Panel, justices, judges, court of appeals judges, all nine of them got together and they reconsidered what the three judges had done. And those nine justices came back and said, no, no, no, the stay stays in effect. So the BOI reporting is no good. Very same thing could happen here. Again, the three judge panel could say yes, it stayed. So everything keeps going. Then the nine judge panel literally within seven days would come back and say yes or no, we confirm it or we don't confirm it, that it is going to stay and stay in place. The law will stay in place and everything keep going while we consider the appeal.
[00:24:42] Who knows what's going to happen?
[00:24:44] So all this takes time. All this takes a lot of time.
[00:24:48] So what we've been telling people and Alta, I know American Land Title association, which is the association of all the title underwriters and a lot of title agents in the United States, they said, hey, it's a business decision for you, but we recommend that you continue collecting the information. And I have to agree with them on that. I would recommend if you're a title agent, if you're doing closing still and it is a residential non finance transaction into a trust or an entity, I would still recommend that you still collect the information.
[00:25:21] However, the deadline for filing that information in the BSA database is within 30 days after closing. So you can collect all that information and then just hold it. You don't have to submit it yet.
[00:25:34] So you could just say, okay, fine, I'm going to click and I'm going to hold and I'll hold this information and I'll put it on my calendar 30 days out at 28 days. I'm going to file it and you're going to let the parties know, hey, we collected this information.
[00:25:49] It's in flux right now. We don't know what's happening with the courts. You hold us harmless. We may have to file it, we may not have to file it, but in any event we're going to collect the information, we'll hang on to it. If the court comes back and says that that order is stayed, that means the rule is still in effect.
[00:26:06] We'll go ahead and file it. If the court comes back and says that the order is not stayed, that it is in effect, then that means that the rules invalid and we will just continue to hold your information. We won't file it until we get confirmation. One of the things that we are hoping will happen is very quickly that FinCEN will come forward and give us clear bright line direction of exactly what they want they did this with BOI reporting.
[00:26:40] They just kept. Except in BOI reporting, BOI reporting never really went into effect 100%, although some people went ahead and filed by the deadline. But FinCEN, they just kept delaying implementation of the rule. I could see FinCEN saying, you know, well, okay, what we're going to do is we are going to stay the rule ourselves. We're going to comply with the court's order. Nobody has to file for any closings, and we are going to instead implement this rule. We're going to wait until the court comes back and tells us whether we violated the Administrative Procedures act or not. In appeals. It could go all the way to the Supreme Court because at that point, you would have two rulings at least.
[00:27:19] Orlando's ruling and a Tyler's ruling in Texas saying that there is a split in the two districts. Now, if that fidelity does not appeal the order of summary judgment that was entered in Orlando, then you just really have a district court case.
[00:27:36] You don't have a split between the courts of appeal. You just have a trial court case and then a trial court case that did go to appeal.
[00:27:44] And so at that point, the Supreme Court may not step up. They may go, well, you know, fifth District Court of Appeals, whatever they decide was good enough, and we'll go with it. It'll be totally in the court's discretion as to whether to hear it or not. Now, the wild card that's thrown into all this is Puerto Rico, because the case was also filed, and I wrote about this in the newsletter as well, a couple of weeks ago that the.
[00:28:07] They filed a case. Another plaintiff filed a case in Puerto Rico saying that the rule violates the privacy of the parties. It's a privacy overreach.
[00:28:20] I don't know how good that is, but I really think, I mean, the apa, the, the Administrative Procedures act case is probably the best method, the best route that a plaintif had to challenge this, especially with the Supreme Court's prior ruling a year or so ago on injunctions. The judge didn't say, well, it's unconstitutional and I'm going to enter an injunctive relief that you cannot enforce this rule. They said the rule violates the APA and it's vacated. The rule is just vacated.
[00:28:50] Now, judges can do that with rules. They cannot do that under the Administrative Procedures Act. They cannot do that with laws. They, they can declare.
[00:28:58] They can find that a law is unconstitutional or constitutional, and then they would enter an injunction as to whether the law is enforceable or not. That's where the court, Supreme Court said this only applies in that district, it does not apply nationwide. We're not going, we're not going to let these district courts, you know, hamstring the entire country. 1, 1 District Court Judge in, in Texas is not going to have any effect on a judge in Oregon or something like that or what happens in Oregon.
[00:29:27] So this is where it stands right now. Summary is the law. It's very much in flux. We're hoping to get some more information from FinCEN one way or the other in the next week or so, week or two. The executive branch, as you can imagine, is extremely distracted right now with other issues in the Middle East. There's some files out there that people demand release of. There's all kinds of other things going on across the country around the world.
[00:29:54] And that's why, I mean, when I kept writing about the FinCEN rule in the newsletter coming up, when I was always talking about it, it was always with the eye toward this is going to be delayed anyway. It's going to be delayed. The administration doesn't like it. They never wanted it in the first place, tried to veto it once, got overridden. So I think they're just going to keep delaying and they didn't delay it. I think it was really just overlooked.
[00:30:17] As I said, I think FinCEN and the courts think that there are not many transactions that are non financed residential purchases into LLCs and land trusts. They simply don't grasp the magnitude of it. Especially in states like Texas, Florida, Georgia, North Carolina, South Carolina, Illinois, California where there is an ex, in Arizona, Utah, Nevada. There is an extremely active investor real estate investor market, small real estate investor market where these folks constantly are buying distressed real estate through one form or another, not using institutional financing. They are buying that property, that residential property, they're taking it into land trusts. In states that they allow that, they're taking it into LLCs and other states for asset protection and privacy reasons and then they are fixing the properties up and reselling them. They really don't believe that they had a true grasp of how big that market is and how many transactions that was going to encompass. Because I mean we, we alone do probably 10 closings a week in or out and we are trusts buying or selling properties.
[00:31:30] So that is very, very common. I know from, from our point of view, it's every single closing almost as far as coming into a trust whenever there's a transaction behind it.
[00:31:40] So that is, you know, where it all stands for title companies, law firms, others who are involved in these transactions. For now, I agree with American Land Title association, you should still continue to collect the information. Having been in title for over two decades, I understand the plight. You're sort of caught between a rock and a hard place. You got a client, your, your, your buyer over here who is screaming, I don't want to give you this information. Maybe it's the source of the funds, maybe it's a private lender and they're like, I don't want to give you this information. That's why I have trust, that's why I have LLC that lend this information, lend this money. I don't information out there.
[00:32:17] But.
[00:32:18] And then by the same token, you've got FinCEN over here that, well, at any point they could come back and say, well, if you're not gathering this information and you're not reporting it to us and you're doing it willfully, we can prosecute you criminally for doing that willfully. So until we get more definitive answers, I say continue to collect the information, hang on to it as long as you can. But if you're bumping up on that deadline to get it filed, go ahead and file it. With that said, everybody goes, okay, well then it goes into this database. Now what? Well, we had exactly the same problem with the BOI reporting on entities, LLCs and corporations.
[00:32:55] And it was slipped in in a hearing with FinCEN in September 2025. And if you weren't watching, you missed it. But in September 2025, during a congressional hearing, a representative of FinCEN said, hey, by the way, we are currently making a rule that will allow us to delete all of the information that was collected from US Companies under that BOI reporting rule we had originally promulgated.
[00:33:28] So we're going to delete all that. I don't know if that rule has come out yet. I haven't dug into that. But I know in September 2025 they told Congress, we're going to work on a rule where we're going to just delete that information. If this rule is deemed to be vacated on residential real estate reporting, FinCEN is probably going to do the same thing. They're going to, they're going to get permission, they're going to make a rule and the rule is going to be pretty simple. We make a rule that all data on non US Companies is being deleted from all of our databases. That'll happen. You know, that was reported under the BOI reporting rule under the Corporate Transparency act is now, is going, shall be deleted within 30 days and then they have a comment period, they have a hearing period and then they they do it. I have a feeling if this law is truly vacated and FinCEN rolls over, plays dead and says okay, fine, we don't care, it's over, let it go, then they will likewise make a rule that they can just delete whatever information that they did collect since March 1, 2026 from all non financed residential real estate transactions into trusts and partnerships. So if you want to keep up with news like this, subscribe to this channel. Look down below. Subscribe to our newsletter so that you'll at least get weekly updates.
[00:34:47] Because I report about this kind of stuff every single week in our weekly newsletter. Along with other things in there. We always have some business coaching advice as well, because that's really why we're in. All this is to try to help your business succeed for those who aspire to a better life.
[00:35:03] Thanks for listening to this edition of Trust this. If you got something out of it, please press like and subscribe and give us a five star review to help us reach others who can benefit from this series. Until next time, keep aspiring to a better life.
