On May 11, 2026, FinCEN has filed a notice of appeal the court order that vacated the reporting requirement. FinCEN still states that reporting persons are not currently required to file residential real estate reports and are not subject to liability for not filing while the court order remains in force. Reporting requirements may change as this appellate action proceeds. Please monitor this portal and FinCEN communications for updates. The portal will remain open for data collection and reporting.