When wire fraud occurs, the loss of funds can be deeply distressing. That pain is now often compounded by the legal baseline for 鈥渞easonable care鈥� dramatically shifting. Courts no longer view wire fraud or deepfakes as unavoidable cyber events or tragedies.

Title agents now face escalating legal risks and negligence liability. Cybercriminals are increasingly leveraging deepfakes in social engineering and business email compromise (BEC) to orchestrate real estate wire fraud and seller impersonation schemes.

If an agency fails to use basic, reasonable defenses like multi-factor authentication or automated ID and bank verification platforms, judges are increasingly finding them liable for lost funds under negligence and breach claims.

In addition to the security measures used, a court or jury will likely also consider the overall reasonableness of the title company鈥檚 wiring procedures. They will review the steps agencies took to safeguard wire transfers and verify their authenticity.

Did the agent double-check the sender鈥檚 email address? Did the agent follow proper procedures to detect communication peculiarities, like grammatical errors or whether an unsecured email was used? Did more than one employee review the communication? Did they confirm the wiring instructions in a second, alternative mode of communication? These are just a few questions that a court might ask when assessing liability.

Agencies can reduce their exposure by strictly adhering to procedure. Carefully reviewing and authenticating all communication not only minimizes susceptibility to wire fraud schemes but also the chances that a court or jury will find the agent negligent.

All agents are at risk of ID and wire fraud-related cybercrime. Whether they are direct victims of the fraud or simply involved in a fraudulent transaction, agents face a real possibility of being held liable. Wire fraud schemes also continue to grow more pervasive and sophisticated with each passing year, which makes reasonable and prudent anti-fraud controls critical to prevent financial losses. Some best practices include:

• Requiring two forms of communication/authentication before issuing a wire;
• Using multi-factor authentication;
• Using an anti-fraud tool on every transaction;
• Educating and training employees in data security and maintaining evidence records; and
• Using secure, encrypted email with passwords and digital signatures for messages.

Using these precautions decreases the risk of fraud and makes it easier to defend against civil litigation should your agency unfortunately fall victim to one of these schemes. Title agents should also carry standalone, comprehensive cyber insurance. This adds an essential, additional layer of protection against both fraud-related crimes and their resulting liabilities.

Have questions about strengthening your agency鈥檚 wire fraud prevention practices or technology due diligence? Contact Tom Weyant at tweyant@alliantnational.com.

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Recent developments surrounding FinCEN鈥檚 Real Estate Reporting Rule (Rule) are creating uncertainty for title and settlement agents. Two federal courts have issued directly conflicting decisions on the validity of the Rule, resulting in an unusual and rapidly evolving regulatory environment. FinCEN has also spoken on the matter. The following provides an overview of what this means for title and settlement agents.

What Just Happened?

To understand the implications of this situation, it is helpful to revisit the Rule itself. FinCEN originally created the Rule to require reporting of certain information regarding parties and bank accounts involved in non-financed purchases of residential real property by entities or trusts. A Florida court said the Rule is valid and placed no limits on the Department鈥檚 ability to act. However, a Texas court said that FinCEN lacked the authority to create such a Rule and threw it out.

Recognizing the confusion that two conflicting decisions and their outcomes signify, FinCEN promptly posted an alert to its :

In light of a federal court decision, reporting persons are not currently required to file real estate reports with FinCEN and are not subject to liability if they fail to do so while the order remains in force.

The Disagreement

In the Florida federal district court鈥檚 view, the government needs flexibility to fight money laundering. If certain types of transactions are risky, the court reasoned, it is permissible to require reporting broadly. The Texas court took a narrower view, holding that the Rule improperly applied suspicion to all transactions rather than targeting specific high-risk activity. These differing interpretations reflect fundamentally different views of the scope of federal regulatory authority.

From an operational standpoint, it鈥檚 important to note that the Texas court did not just block the Rule鈥攊t wholly invalidated it (for now). Title and settlement agents are not required to report under the Rule at present. This situation may change, however, so continued monitoring is crucial.

FinCEN is expected to appeal the Texas decision to a federal appellate court, while the Florida case may also proceed through the appellate process. As part of this process, FinCEN may seek a stay of the Texas ruling. If a stay is granted, the Rule could be reinstated with little or no advance notice, immediately reimposing data collection and reporting obligations on industry participants. Should the appellate courts disagree, this dispute over the Rule could be headed to the U.S. Supreme Court.

Exploring Options

In the interim, title and settlement agents must determine how to approach compliance in a period where the Rule is not currently enforceable but may return with limited notice.

Some organizations have elected to continue collecting the information required under the Rule in order to maintain operational continuity and avoid the risk of scrambling to comply if the Rule is reinstated. This approach can reduce the likelihood of retroactive challenges and preserve established workflows, but it also introduces additional administrative burden and may create friction with customers who question the necessity of providing sensitive information.

Other organizations have chosen to suspend data collection activities until there is greater legal clarity. This approach aligns with the current regulatory posture, eliminates unnecessary work, and avoids the collection of sensitive data in the absence of a clear federal mandate. However, it carries the risk of requiring rapid operational adjustments if the Rule is reinstated with limited notice.

A third approach has emerged as a practical middle ground. Under this model, organizations maintain readiness by preserving internal processes, continuing staff training, and retaining necessary forms and workflows, while refraining from actively collecting data unless and until the Rule is reinstated. This approach balances preparedness with operational efficiency during a period of uncertainty.

As if this wasn鈥檛 confusing enough, I should note that additional outcomes are also possible. For instance, it is possible that FinCEN may revise the Rule in response to the Texas court鈥檚 concerns if the agency does not prevail on appeal. Future implementation timelines may also change, potentially including new deadlines, phased rollouts, or substantive modifications. However, at present, there is no reporting obligation for past transactions, and retroactive reporting requirements are considered unlikely.

What to Do in the Meantime

In communications with customers, real estate professionals, and attorneys, a clear and consistent message is advisable: the Rule is not currently in effect due to a federal court decision, and organizations are actively monitoring developments and will adjust their processes if reporting requirements are reinstated.

While the current situation reflects a degree of legal uncertainty, it also provides a window of opportunity. Title and settlement agents are not required to comply with the Rule at this time and can use this period to evaluate processes, prepare for potential changes, and ensure that they are positioned to respond effectively as the regulatory landscape evolves. Importantly, it is comforting to remember that the industry, as a whole, is all in the same boat.

Final Thought

While the current landscape is indeed uncertain, these developments reflect the legal system functioning as intended, with courts examining the limits of regulatory authority and evaluating the policy considerations underlying the Rule. As this process continues through the appellate system, it will ultimately provide greater clarity on the scope and enforceability of federal reporting requirements in real estate transactions. In the meantime, agents should remain informed by monitoring FinCEN鈥檚 Residential Real Estate Rule webpage for updates: . Your 星空传媒 星空传媒 underwriting is also available to address questions or concerns as the situation develops.

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Every wire fraud defense expert agrees on one thing: the number one factor in recovering diverted funds is time. Every minute counts once fraud is detected, and hesitation or delays can make it harder to track down and restore lost funds.

That鈥檚 why a wire fraud response plan is imperative for every title agent.

The American Land Title Association (ALTA) recommends that every title company develop, document and train every staff member in the critical first steps for effective responses to wire fraud incidents. , can help agencies prepare to respond quickly and effectively as outlined in key points highlighted in this article.

Elements of a Wire Fraud Response Plan

The first step in preventing fraud is maintaining strong policies and procedures for verifying the identities of parties to the transaction and wire instructions to protect all parties: Buyer, seller, lender, underwriter and title agent. 星空传媒 星空传媒 agents are urged to implement procedures making sure to Verify, then Trust – every file, every party, every time.

But if the unthinkable happens, the most successful response strategies are those established in advance and clearly communicated to all staff members, banking partners and transaction participants.

Like a well-trained sports team, every member of your organization should understand their role and be ready to act immediately if fraud is detected.

General protocols

• Establish a close relationship with your bank representatives and maintain regular communication about emerging fraud threats and response procedures.
  • Make sure you have a phone contact that is not an 鈥�800 number鈥� to avoid delays.
• Discuss wire retrieval scenarios with your bank and establish emergency contacts in the bank鈥檚 fraud department that can be reached immediately if fraud is suspected.
  • Share this information with every employee as first reactions are critical.
• Establish and document emergency contacts across your response network, including bank fraud departments, law enforcement, legal counsel and your underwriter.
  • The local FBI office and the Secret Service office in your region should be included in this contact network.

Rapid response actions

• Your staff should be trained to immediately alert company management and the ageny鈥檚 internal wire fraud response team if a suspicious or potentially fraudulent transfer is detected.
  • Encourage transparency as delay or fear of retaliation for errors can cause losses to increase.
• Contact the sending bank鈥檚 fraud department immediately and request a recall of the wire transfer due to suspected fraud. Ask the bank to initiate the FBI鈥檚 鈥淔inancial Fraud Kill Chain Process鈥� if applicable.
• Notify the receiving bank鈥檚 fraud department and request that the account receiving the funds be frozen pending investigation.
• Report the incident to appropriate law enforcement agencies, including your local police department, the FBI field office serving your jurisdiction, as well as Secret Service teams.
• File a complaint with the FBI鈥檚 Internet Crime Complaint Center (IC3) as quickly as possible via their website, .
• Inform the parties to the transaction using known, trusted phone numbers and established communication channels.
• Notify your underwriter and coordinate next steps. 星空传媒 星空传媒鈥檚 Claims Team and Underwriting Counsel are available to assist agents in evaluating and responding to suspected fraud events.
• Contact your own agency legal counsel to assess potential liability and assist with recovery efforts.
• Depending on the circumstances, notify appropriate insurance carriers such as cyber liability, escrow security bond or errors and omissions insurers.
  • Do not delay these notifications as missed deadlines on notices can result in a claim denial and financial losses for your agency.

Putting all of these resources in motion immediately is critical to securing the support of professionals or organizations with tools that could assist you in recovering the diverted funds.

The FBI鈥檚 Internet Complaint Crime Center, , is one of your most important contacts. According to the FBI鈥檚 2024 Internet Crime Report, the IC3 Recovery Asset Team initiated the Financial Fraud Kill Chain on 3,020 complaints involving $848.4 million in attempted theft[i]. Financial institutions were able to freeze $561 million of those funds, representing a 66% success rate.

The effectiveness of this process depends heavily on how quickly fraud is reported, which is why having a response plan in place and acting immediately is critical.

Even the most vigilant companies may fall victim to fraud, but having a clear response plan and trained team in place can significantly improve the chances of recovering lost funds.

As always, immediately reach out to your 星空传媒 星空传媒 Claims Team and Underwriting Counsel if you have any questions or concerns. Together we can fight fraudsters, but always remember to take the steps to stop fraud and Verify, then Trust – every file, every party, every time.

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By Adam Mohrbacher

From the rolling hills of Missouri to the coastal plains of Florida, fraud continues to threaten real estate transactions across the country. In response, an increasing number of 星空传媒 星空传媒 agents are answering the call to help identify and stop fraudulent activity. Over the years, these agents have prevented dozens of fraudulent transactions from moving forward, saving millions of dollars in proposed liability. Here, we take a closer look at fraud prevention efforts from the past year, as well as the agencies recognized through 星空传媒 星空传媒鈥檚 Crime Watch program.

A problem with a massive scope

Not that anyone really doubts it, but the data continues to confirm that real estate fraud in the United States is pervasive. ALTA鈥檚 2025 Cybercrime Study, for example, showed that over 40% of title companies reported getting at least one email per month attempting to change wire instructions.[i] A survey from the 星空传媒 Association of Realtors paints an even more disturbing picture, with 63% of respondents indicating they were aware of deed/title fraud in their markets within the past 12 months.[ii]

In her recent claims wrap-up blog, 星空传媒 星空传媒鈥檚 Chief Claims Counsel, Mauri Hawkins, also emphasized that title and real estate fraud is arguably getting worse鈥攏ot better. 鈥淚n my opinion, it appears there has been an increase in the number of submitted title claim notices involving lawsuits challenging the validity and veracity of recorded real property instruments or the authority of a person to execute documents on behalf of a person or entity in the chain of title,鈥� she noted.

The sheer amount of fraud is not the only problem the industry is facing. Fraudsters鈥� increasingly advanced methods also pose a clear threat. They are 鈥渓everaging social engineering and devices to manipulate, influence and deceive; they continue to prey on what they see as a lucrative market and a quick payday,鈥�[iii] said Hawkins.

The role of 星空传媒 星空传媒 agents

Many 星空传媒 星空传媒 agents have continued to push back against this ever-rising tide of fraud across the United States. In 2025, their vigilance resulted in $1.6 million in savings. 星空传媒 星空传媒 helped support and incentivize these efforts through its Crime Watch program. The program issues $1,000 each time an eligible agent who meets the program criteria discovers and prevents fraud. The program awarded $11,000 to agents in 2025 alone, reinforcing 星空传媒 星空传媒鈥檚 commitment to proactive fraud prevention.

星空传媒 星空传媒鈥檚 2025 Crime Watch Award Recipients:

What agencies can do

There are many lessons agencies can draw from these real-world experiences. Aransas County Title鈥檚 Brooke Turner, who prevented a nearly $250K transaction from going forward, explained that: 鈥淲e look at everything associated with identities and banking accounts鈥攊ncluding handwriting. If the handwriting on recorded documents doesn鈥檛 match the contract or wiring instructions, it鈥檚 a huge red flag.鈥�[iv] 

Tropics Title Services鈥� Jean Thomas, who blocked a fraudulent $23K transaction, echoed Turner鈥檚 comments on the importance of being comprehensive, as well as having strong internal protocols in place. 鈥淚 followed my gut, adhered to best practices and followed our tried-and-true policies for dealing with suspicious activities,鈥� Thomas reflected. 鈥淔raud is not going away in this industry, unfortunately,鈥� she continued. 鈥淲e must ensure that we thoroughly investigate any deals that carry sufficient red flags.鈥�[v]

These efforts align with 星空传媒 星空传媒鈥檚 new Verify, Then Trust initiative鈥攄esigned to raise awareness and reinforce best practices that help stop fraud before it becomes a claim. Agents are urged to Verify, Then Trust on every file, every party, every time.

Additional best practices aligned with a 鈥淰erify, Then Trust鈥� mindset include:

• When possible, always speak to the customer directly rather than relying on digital communication.
• Always encrypt sensitive information such as wire instructions.
• Foster a highly collaborative agency culture to ensure collective expertise is brought to bear on suspicious transactions.
• Stay up to date on the latest news and trends related to real estate fraud and title claims. The 星空传媒 星空传媒 website blog remains a phenomenal source of information on everything from claims and cybersecurity tips to how to prepare for a data breach.
• Take advantage of continuing education classes offered through that focus on fraud, cybersecurity and compliance.
• Remember: when something feels off with a transaction, it probably is. Trust yourself and take action. As they say, it鈥檚 always better to be safe than sorry.

Make this a year of anti-fraud activity

Whether your agency is well-versed in addressing fraud or just beginning to put formal policies in place, now is the time to act. Working collaboratively with 星空传媒 星空传媒 can help support your efforts to identify and respond to potential fraud. Let鈥檚 continue working together to promote a safer and more successful industry鈥攂y remembering to Verify, Then Trust. Want to learn

[i]

[ii]

[iii] Claims: A Look Back At 2025 – 星空传媒 星空传媒 Title Insurance Co.

[iv] Texas Title Agent Spots Red Flags, Stops Dubious Deal – 星空传媒 星空传媒 Title Insurance Co.

[v] Two 星空传媒 星空传媒 Agents Take the Fight To Fraudsters – 星空传媒 星空传媒 Title Insurance Co.

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As fraud tactics evolve, so must the way the industry protects consumers and transactions. That鈥檚 why 星空传媒 星空传媒 has launched Verify, Then Trust鈥攁 new initiative designed to raise awareness and reinforce best practices that help stop fraud before it becomes a claim. Agents are urged to Verify, Then Trust on every file, every party, every time.

The Rise of Deepfake Fraud in Real Estate

Deepfake fraud has been making headlines in unexpected ways, and real estate is one of the latest industries to be hit. In the past two years, fraudsters have leveraged AI-powered deepfake technology to pose as property owners, financial executives, and even notary publics. Even experienced agents working with what they think are repeat or loyal customers have suffered devastating losses.

Take, for example, a case from 2023 where a scammer used a deepfake voice to impersonate a real estate attorney in communications with a client. The unsuspecting buyer believed he was speaking with his legitimate attorney and wired a six-figure down payment鈥攕traight into the scammer鈥檚 account.

Another shocking case involved a fraudster using a deepfake video to pose as a property owner looking to sell a luxury home. The scammer managed to fool not only the buyer, but also the title company, leading to the fraudulent sale of a multimillion-dollar estate.

Of course, there was also the fraudulent attempt to force a foreclosure sale of Graceland, Elvis Presley鈥檚 home, which made headlines in 2024. These fraudsters are bold and believe that increasingly large and high-profile targets can yield even bigger payouts.

How to Combat Deepfake Fraud in Real Estate

With deepfake technology becoming more advanced, spotting fraud with the naked eye is harder than ever. But that doesn鈥檛 mean we鈥檙e powerless. Here are some strategies to avoid falling victim:

Double-Verify Identities
Don鈥檛 rely solely on phone calls, video calls, or emails. Always confirm identities through multiple channels鈥攕uch as in-person meetings, official documentation, letters via 鈥渟nail mail,鈥� and voice confirmation through previously established phone numbers. This is even more critical in vacant land transactions or refinances involving free and clear properties.

Use Multi-Factor Authentication (MFA)
When transferring funds or signing critical documents, consider requiring multi-factor authentication (MFA). This adds an extra layer of security beyond visual or voice verification alone. It鈥檚 always important to treat funds with great care鈥攁s if the money were your own鈥攁nd take appropriate steps to protect them. If funds go missing, customers may seek reimbursement from the agent鈥檚 personal account.

Scrutinize Video Calls and Emails
If something feels off鈥攍ike unnatural blinking, delayed audio sync, or robotic speech patterns鈥攂e skeptical. Deepfake videos often have subtle imperfections that can give them away. Ask probing questions a deepfake would not be able to answer accurately. You may even want to establish a special passphrase with customers, provided to them only through a secure portal.

Conduct Due Diligence
If a new client or seller suddenly appears with urgent demands, do your due diligence. Check property records, verify business affiliations, and ensure everything aligns with known facts. As they saying goes: If it appears too good to be true, it probably is. Scammers also like to amp-up the pressure, so do not let a hurried closing or pushy customer cause you to shortcut your verification processes.

Leverage Fraud Detection Tools
Just as AI is being used to create deepfakes, it鈥檚 also being used to detect them. Some AI-driven tools analyze facial movements, voice anomalies, and inconsistencies in digital assets to help identify fraudulent activity. In the real estate space, tools such as CertifID add another layer of confidence to the process. 星空传媒 星空传媒 agents can now use CertifID with discounted pricing to protect deals by verifying identities, managing and ordering payoffs, and securing wire instructions. Verify, then Trust 鈥� every file, every party, every time.

The Bottom Line

Deepfake technology is no longer a futuristic concern鈥攊t鈥檚 here, and it鈥檚 changing the way fraudsters operate. By staying vigilant and implementing multi-layered verification methods, you can ensure that your next property transaction doesn鈥檛 turn into a deepfake disaster. Remember: Verify, Then Trust 鈥� every file, every party, every time.

See 星空传媒 星空传媒鈥檚 recent , which was inspired by a real-life attempt to commit wire fraud using deepfake technology.

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Planning ahead is second nature in the title world鈥攜ou juggle deadlines, details, and documents every day. But when it comes to new compliance rules, a little extra structure can make all the difference. That鈥檚 why we鈥檝e put together a host of resources, including a step-by-step project plan to help title agents prepare for the Residential Real Estate Rule, expected to take effect on December 1, 2025.

This plan is designed to keep things simple. Instead of re-inventing the wheel, it walks you through what to do week by week, with plenty of shortcuts (like suggested vetting questions to ask vendors) so you can stay focused on your closings.

Here鈥檚 a quick look at what the plan covers:

• Week 1鈥�2: Get familiar with the rule, assign a compliance lead, and choose your tools (forms or vendor).
• Week 3鈥�4: Vet vendors (if you鈥檙e going that route), decide who files reports, and build in checks so nothing falls through the cracks.
• Week 5鈥�6: Train your team, run a couple of test files, and see how your process really works in practice.
• Week 7鈥�8: Fine-tune, double-check your system, and go live鈥攃onfident that every file is handled the right way.

The plan also includes a one-page daily checklist that makes it easy for staff to follow along. From the moment a file opens to the moment the report is submitted, the checklist spells out what needs to happen so everyone is on the same page.

Think of it as a roadmap for compliance: clear, practical, and (dare we say) less overwhelming than it sounds. By starting now, you鈥檒l avoid the stress of last-minute changes and be fully prepared to hit the ground running on December 1.

Download the full project plan today and give your team a great head start!

That鈥檚 not all!

星空传媒 星空传媒 is also hosting a live webinar on October 2 at 1 pm ET to help agents prepare for the final rule. You can register for the live webinar . Webinar recordings will be available in early October.

鈥�.And, we鈥檝e built a dedicated RRER Resource Page with in-depth guidance, definitions, exemptions, and tools to help you understand and implement the new reporting requirements. You can explore it here: /rrer/

Of course, if you have additional questions, please reach out to your 星空传媒 星空传媒 State Underwriting Team. We鈥檙e always happy to help!

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Wire fraud is evolving fast, driven by sophisticated criminals using AI tools. How can you protect your business? Join Tom Weyant, Risk Management & Data Privacy Officer at 星空传媒 星空传媒, and Jerome Magana, Owner and President of Select Specialty Insurance Services as they unpack the latest trends in cybercrime and emerging threats specifically targeting real estate transactions. Learn why traditional defenses might be falling short, how insurance coverage requirements are changing, and practical steps you can immediately take to safeguard your business.

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Mary Poppins鈥� famous line, 鈥淛ust a spoonful of sugar makes the medicine go down,鈥� simply does not work for compliance with FinCEN鈥檚 Residential Real Estate Rule (Final Rule). You can approach it with a good cup of coffee or tea by your side, along with your favorite tasty treat (did anyone say 鈥渓emon poppyseed cookie鈥�?), but you can鈥檛 sugarcoat the truth of it.  Collecting up to 111 data points and transcribing them into a complex reporting form promulgated by FinCEN is no easy feat. However, efforts are underway to make compliance with the Final Rule more understandable, bearable, and easier to achieve. How so, you may ask?     

In our last blog about FinCEN鈥檚 Final Rule, we briefly described a comprehensive two-day ALTA FinCEN Bootcamp training session held on June 2 and 3, 2025. Now we鈥檙e going to go a bit more in-depth with our coverage. 

Over the course of those two days, numerous speakers presented a variety of topics geared at providing background information, operationalizing advice, implementation requirements, and training materials for compliance with the Final Rule:

• Overview of Bank Secrecy Act (And Usefulness Of The Data Collected Under It)
  • Money Laundering and Real Estate
    • Real Life Examples Of Bad Actors Using Real Estate For Money Laundering; Resulting Real Estate Forfeitures And Treasury Auctions
  • 411 on FinCEN Residential Real Estate Rule (31 CFR 1031.320(b))
    • Who, What, When & How to Determine A Reportable Transaction
    • Expectations for Training, Reporting, and Record-keeping Costs
    • Penalties for Non-compliance (Civil & Criminal)
    • FAQs
    • Suggested Contractual Language for Residential Purchase Contracts
    • Suggested Schedule B-1 Commitment Language
    • Current Industry Lawsuits Against FinCEN
  • The Rule in Action (Hypothetical Scenarios)
  • How to Train Your Customers (Providing A Sample PowerPoint presentation For A 鈥淟unch & Learn鈥� That Can Be Branded And Used By ALTA Members)
  • The Collecting Is The Hardest Part (Data Points and Information Collection Forms)
  • Fun with Filing (How To Do It 鈥� Using The BSA-EFiling System)
    • Review Of 鈥淲ho鈥� Files per the Rule (i.e. The 鈥淲aterfall Cascade鈥�)
    • Designation Agreements For Someone Else to File
    • Registration For EFiling
    • System Requirements
    • Volume Of Covered Transactions
  • Training Your Staff
    • Selecting Subject Matter Expert (SME) Employees
    • Resources (FAQs, Published Rule)
    • Workflow Considerations
    • Record Retention And Storage
    • Staff Impact; Company Communications; Training for the Reporting Person

As you can see from the list above, there is a LOT to learn and do in order to prepare for the Final Rule鈥檚 impending effective date of December 1, 2025. Discussions about the new and Information Collection Forms developed by ALTA were incorporated into the training. These are complex forms intended to help the buyer鈥檚 and seller鈥檚 representatives provide all of the required data that will ultimately be included in the report to be filed through the BSA EFiling network. To access these forms via the hyperlinks provided, you must be logged into the ; these forms are available to ALTA members and to those who obtain a license to use ALTA鈥檚 policy forms. At the end of each form is a certification page for the seller鈥檚 and buyer鈥檚 representatives to sign, certifying to the completeness and accuracy of the information provided. We anticipate that these forms will be widely used across the industry, so it is important to understand and be familiar with them.

The idea behind the training is that if the rule, the requirements and the process are understood by all key stakeholders 鈥� including the real estate sales agents as well their customers 鈥� then securing their cooperation for data acquisition will be much easier for the closing agent charged with reporting to FinCEN. The ALTA Bootcamp segment entitled 鈥淗ow to Train Your Customers鈥� is tailored to educate everyone about the law and what they need to do to comply. For those of you who did not attend the Bootcamp, or who want a refresher, 星空传媒 星空传媒 plans to provide its own training to real estate sales agents toward the end of the summer and you are welcome to attend.

We have developed an 星空传媒 星空传媒 branded presentation, which you can also co-brand with your agency鈥檚 name, for you to offer to customers and real estate professionals. In addition, we will be offering a deep dive into the Final Rule starting in late summer or early fall presented by the 星空传媒 星空传媒 underwriting and education teams. This training will help you identify reportable transactions, understand available exemptions to the rule and navigate potential pitfalls which could result in non-compliance and potential penalties. The goal of this presentation will be to train our agents to be experts on the Final Rule well in advance of its December 1, 2025, effective date.  In the interim, we encourage you to monitor industry and 星空传媒 星空传媒 publications on FinCEN, review FinCEN FAQs currently available, , practice a dry run into the BSA Efiling Network, https://boir.org/, and speak to your production software vendor about their plans for an integrated filing process. It is never too early to start the process regarding the Final Rule.  

The post Preparing for the FinCEN Final Rule 鈥� and Its 111 Data Points appeared first on 星空传媒 星空传媒 Title Insurance Co..

Here鈥檚 a riddle for the title insurance and real estate industries: what does Dolly Parton鈥檚 song, 鈥淗ere You Come Again鈥� have to do with FinCEN, its Geographic Targeting Orders (GTOs), and its Final Real Estate Report Rule (Final Rule)?  Answer: the last verse of the song repeats the lyrics, 鈥淗ere you come again . . . And here I go鈥� several times, analogous to FinCEN鈥檚 multiple, back-to-back, ever-expanding GTO鈥檚 issued since 2016, culminating in its permanent Final Rule issued on August 28, 2024, and effective on December 1, 2025, and our efforts to adapt and comply with all of its changes and requirements. 

We first published a in November of 2024 discussing FinCEN鈥檚 Final Rule, its anticipated effective date of December 1, 2025, and the  things you should be thinking about to get an early start on operationalizing compliance with the numerous requirements.  Well, a lot has happened since then鈥攍et’s bring you up to speed.

What has the industry been up to?

First of all, industry stakeholders have been diligently working to try and reduce the impact of the Final Rule on your title insurance business. Some players have even started pushing back hard against the Final Rule.

• On April 14, 2025, East Texas Title  filed suit in the U.S. District Court, Eastern District of Texas, to get an injunction against the permanent FinCen Real Estate Rule from going into effect on December 1, 2025. Some of the legal arguments:
  • Violation of the Constitution鈥檚 separation of powers 鈥� title agents should not be 鈥渇orced to perform government surveillance on their clients by reporting private information from legitimate transactions鈥�
  • Constitution only grants Congress the power to regulate commerce between states and that the federal government has no standing to require businesses to collect information on real estate cash transactions that take place entirely within Texas
  • Fourth Amendment protects against 鈥渦nreasonable searches and seizures鈥� of 鈥減ersons, houses, papers, and effects,鈥� including business record – no right to require private business to violate the privacy of Americans.
    
• On May 20, 2025, a national underwriter  filed suit against Department of the Treasury and Treasury Secretary Scott Bessent, along with FinCEN and its director, Andrea Gacki, in the U.S. District Court, Middle District of Florida, Jacksonville Division.  Some of the legal arguments set out in their complaint include:
  • The rule exceeds FinCEN鈥檚 statutory authority
  • The rule is arbitrary and capricious
  • The rule violates the Fourth Amendment prohibition against warrantless searches
  • The rule violates the First Amendment鈥檚 prohibition on compelled speech
  • The rule exceeds any authority Congress could have delegated under the Commerce Clause or its other Article I powers
    
• On May 15, 2025, ALTA made a formal appeal to the Office of Management and Budget (OMB), asking for the 鈥淎nti-Money Laundering Regulations for Residential Real Estates鈥� Final Rule to be rescinded 鈥渋f changes are not made to lessen the overly burdensome requirements on small title companies.鈥� (See )
  

Second of all, ALTA took the lead and created a working group to develop information collection forms to capture the information required for FinCEN reporting under the Final Rule.  After all, FinCEN鈥檚 initial had 111 distinct fields so there will be a good bit of information to be collected! 

Third of all, ALTA has been working on creating helpful industry training webinars.  The first of these webinars was presented in March 2025 –  Learn How Proposed Real Estate Anti Money Laundering Rule Impacts You 鈥� and is available to watch as a free recording on Youtube at .  The second of these webinars was a comprehensive 2-day FinCEN Bootcamp training session held on June 2 and 3, 2025; while the Bootcamp was not a free event, we will be sharing valuable information from it in our future blogs and in agent training currently under development.  For now, you should know that the big takeaway from the Bootcamp is that it is NOT too early to begin operational preparations for the Final Rule.  It was pointed out that orders for cash transactions received in October and November could very well close in December and therefor be subject to the requirements of the Final Rule, so processes need to be in place to recognize and capture those early orders and ensure your agency鈥檚 compliance.  In fact, settlement agents are encouraged to register for the FinCEN filing portal in advance of the Final Rule鈥檚 effective date by going to and setting up a Supervisory User Account.  You can even prepare a practice report to understand the actual process and even provide your team with training. Just do not hit SUBMIT!

Lastly, on April 17, 2025, ALTA published based upon questions from their customers.  The questions involve numerous scenarios, and the answers do a good job of interpreting and applying the provisions of the Final Rule to the hypotheticals. 

What has FinCEN been up to since it鈥檚 publication of the ? 

On November 12, 2024, it released a to implement the Final Rule.  As with the posting of the Final Rule, the posting of the draft report form also has a preamble discussion, but if you want to skip over it and hop directly to the draft report section in the Appendix 鈥� Real Estate Report Summary of Data Fields, then click here .  

On June 5, 2025, FinCEN announced that the U.S. Department of the Treasury, on behalf of FinCEN, will submit the to the Office of Management and Budget (OMB) for review and clearance in accordance with the Paperwork Reduction Act of 1995 (PRA); the public comment period on the information collection request is open until July 7, 2025.  By law, an agency cannot collect information without displaying a valid OMB number, so this is another required step as FinCEN moves forward with its plans for a final report form to implement its Final Rule.  To skip the preamble and go directly to the Appendix-Real Estate Report Summary of Data Fields, click here .  

What has 星空传媒 星空传媒 been up to?

Members of 星空传媒 星空传媒鈥檚 legal team have participated in developing the ALTA information collection forms and trainings discussed above.  We recognize that all stakeholders in this process will need education to understand the benefits of the Final Rule as well as its impact on residential real estate transactions after December 1, 2025. Stay tuned for practical 星空传媒 星空传媒 agent training webinars starting later this summer. We will also offer programs for your real estate professional partners as their support of your information collection efforts will be critical to a smooth closing under the Final Rule. We are already working to train our internal team members so you will have a team of experts at your disposal. Then we will help 鈥渢rain the trainers鈥� so you are equipped to respond and educate your business referring partners as well.  One thing is clear, moving forward the more players in your real estate transaction who are up to date with the benefits of the Final Rule and the protections it offers, the more rapidly acceptance and adaptation will follow. 星空传媒 星空传媒 will be your expert now and as the Final Rule implementation becomes part of your standard operation procedures.  

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In my last blog article, I discussed how deepfake fraud is a growing threat in the real estate industry and what you can do to combat it in your workplace. This time, I thought it would be helpful to take a deeper dive into some of the latest AI tools on the market that may be able to assist in these efforts. Of course, careful consideration is warranted before implementing any new solution, and it鈥檚 important to consult with your IT and security team to ensure it aligns with your business needs and data security standards. With that said, let鈥檚 dig in!

What is deepfake fraud?

Deepfake fraud has exploded in recent years, with some reporting showing an increase of over 2,000%. Scammers are using AI-generated videos and voices to impersonate real people convincingly. To combat this technology, experts have developed cutting-edge tools and techniques to recognize and stop deepfakes.

What are people doing about it?

Here are some of the latest detection methods that your agency might consider to keep deepfake fraudsters at bay. Here鈥檚 how they work.

• AI-powered detection tools听are designed to analyze videos and images in real time to detect whether they have been manipulated. Just a couple promising tools include:
  
  • HONOR鈥檚 AI Deepfake Detection 鈥撎�Launching April 2025
    HONOR鈥檚 deepfake solution can be thought of as a built-in lie detector for images and videos. The technology scans media in real time and alerts users if something seems fake. This could help businesses and individuals avoid being misled by AI-generated content.[i]
    
  • Reality Defender听鈥撎�Real-time Deepfake Detection for Video Calls
    In a world of constant video meetings, it has unfortunately become possible for someone to get on a call with you and pretend to be your boss or a family member by using deepfake technology. Reality Defender combats this type of fraud by scanning facial movements, voice patterns and subtle glitches in real time. If anything is flagged, the technology alerts the user so they don鈥檛 become victims of scams.[ii]
    
• Lightweight AI models听are another tool people are deploying to deal with the rise of deepfakes and other fraudulent activity. These AI detection tools offer unique advantages to users. For one thing, they require far less computing power than other models, but they are still capable of effectively detecting deepfakes. Let鈥檚 look at a specific example:
  
  • Tiny-LaDeDa 鈥撎�A mini AI model with 96% accuracy
    Unlike traditional AI models that suck up an inordinate amount of power, Tiny-LaDeDa can sniff out deepfakes even while running on smaller devices. Despite being lightweight, it still claims to detect 96% of deepfake videos out there by analyzing tiny details in the way faces and voices are generated.[iii]

Comprehensive benchmarking frameworks

Given that deepfake technology is always evolving, cybersecurity researchers are not resting on their laurels. The industry has been developing standardized testing platforms to improve detection tools and ensure that security solutions can keep up with even the most creative of fraudsters. Let鈥檚 take a peek at some of the most notable:

• DF40 鈥撎�A giant deepfake training library
  The DF40 library can be thought of like a gym for deepfake detectors. It contains thousands of deepfake samples created using 40 different AI techniques. Researchers can train and test tools against a wide variety of fake content, which enables them to get far better at spotting new ones as they come online.[iv]听
  
• DeepfakeBench 鈥撎�A fair testing ground
  As with many cybersecurity tools, not all deepfake detectors are created equal. Additionally, some detectors are good at spotting one type of fraud but perform poorly when dealing with another. DeepfakeBench seeks to remedy this by ensuring that every detection tool is tested under the same conditions. It is an important solution for those who want to compare different products and assess which ones are the most effective.[v]

Smarter deepfake detection techniques

Sometimes, deepfake detectors can cause more problems than they solve. For example, certain tools may focus too much on 鈥渇ake-looking鈥� elements instead of checking if a person鈥檚 identity is real by cross-referencing IDs against verified data or analyzing biometric consistency. Luckily, there are many researchers currently working hard to fix this problem:

• Rebalanced Deepfake Detection Protocol (RDDP)
  RDDP improves deepfake detection by making sure tools don鈥檛 just look for obvious digital artifacts like weird lighting or blurry patches. This prevents hackers from bypassing detection by using better-quality deepfakes.[vi]

Government and military efforts

Governments are also stepping into the fight against deepfake fraud, especially because deepfakes can pose a considerable risk to national security and election integrity.

• Defense Advanced Research Projects Agency (DARPA)
  DARPA is an agency within Defense Department that focuses on investigating emerging technologies. As part of that effort, it is investing in AI tools that go beyond simple detection and combat deepfakes on a forensic level. The agency sees this work as a critical piece of the puzzle in dealing with everything from misinformation and identity fraud to protecting against AI-generated impersonations.[vii]听
  

Tools for real estate transactions

While deepfake technology is advancing, so too are the tools designed to prevent all types of fraud in real estate transactions.

• SecureMyTransaction庐 from 星空传媒 星空传媒
  SecureMyTransaction (SMT) leverages AI-driven facial recognition to verify identities by comparing ID photos with selfie images, helping ensure that parties involved in a transaction are legitimate. In addition, SMT helps verify bank accounts and business entities to add multiple layers of security. By integrating these advanced fraud prevention tools into the title and escrow workflow, SMT provides an important safeguard against deepfakes and other fraud tactics. Learn more at.

Final thoughts

Scammers are increasingly using AI-powered deepfakes to target real estate transaction stakeholders鈥攚hich makes them a major threat to our industry. But thankfully, new detection technologies are pushing back on these ambitious criminals. For title agencies, it is imperative to understand how these solutions work and how they may enhance your cybersecurity posture. The threat landscape is always evolving, but by staying apprised of the most cutting-edge solutions out there, you can fight fraud and keep your agency moving forward.

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