Where the legal fight stands for FINCEN:
The litigation over the RRE rule has featured the twists and turns of a courtroom drama.
On March 19, 2026, U.S. District Judge Jeremy D. Kernodle of the Eastern District of Texas vacated the RRE rule in full, stating that FinCEN had exceeded its legal authority under the Bank Secrecy Act of 1970. The decision applied nationwide.
On May 11, FinCEN, through the U.S. Department of Justice, filed a notice of appeal. FinCEN wants the U.S. Court of Appeals for the Fifth Circuit to overturn Kernodle’s decision and reinstate the rule. FinCEN has not requested a stay of the vacatur, meaning the rule currently remains unenforceable while the appeal plays out.
The legal picture is complicated further by a parallel case.
In Florida, a separate federal judge had previously upheld the RRE rule against a challenge brought by Fidelity National Financial. FNF has since appealed that decision to the Eleventh Circuit. Two federal circuits now have active cases on the same rule, pointing toward a potential circuit split that could eventually send the matter to the Supreme Court.
A third case, filed in the U.S. District Court for the District of Puerto Rico by the Puerto Rico Privacy Association and two co-plaintiffs, raises similar statutory arguments against the RRE rule, along with an added challenge unique to Puerto Rico’s legal system. In May, the plaintiffs and FinCEN jointly asked the Puerto Rico court to stay those proceeding pending the outcome of the Fifth Circuit appeal, effectively putting the case in Puerto Rico on hold until the Texas litigation is resolved.
50Deeds.com and 50Fincen.com is here, whatever comes next.
Before being vacated, FinCEN’s RRE rule went into effect March 1st, requiring title & escrow professionals and others to file highly detailed reports on most non-financed residential transactions involving legal entities or trusts. In practice, that meant reporting an estimated 800,000 to 850,000 transactions each year.
Well in advance of the rule’s effective date, 50deeds.com moved quickly to build 50fincen.com —at zero cost for 50deeds.com customers. The solution provides the ability for trust and estate planning attorney to place 50fincen order online at 50fincen.com, automate information collection workflows, securely gather data from transaction parties and track submission status.
“We did this at no cost to customers because that’s what a platform company should do,” said Marie Vagner, Director of Marketing. “When regulation changes, your technology partner should make compliance easy, not expensive.”
50deeds.com's infrastructure remains in place. We’ll continue tracking developments in the RRE legal battle and providing insight as the situation evolves.
Why attorneys choose 50deeds.com:
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Let us manage the paperwork while you focus on high‑value legal work. Ready to modernize your workflow? Visit 50deeds.com to learn more and get started today.