December 17, 2025

In This Issue:

  • Federal Magistrate Recommends District Court Rule in Favor of FinCEN in Suit Challenging Implementation of FinCEN’s New All-Cash Residential Real Estate Reporting Rule That Could Go Into Effect Early Next Year
  • ICYMI: TDI Adopts Due Dates for Annual Submission of Title Insurance Statistical Data Reports
  • TDI Publishes Annual Report, Which Includes Data on Title Insurance Companies and References to the Agency's Work Related to Our Industry

Federal Magistrate Recommends District Court Rule in Favor of FinCEN in Suit Challenging Implementation of FinCEN’s New All-Cash Residential Real Estate Reporting Rule That Could Go Into Effect Early Next Year

TLTA | Dec. 17, 2025

In a document filed last week, a U.S. magistrate recommended that the United States District Court for the Middle District of Florida grant FinCEN’s cross-motion for summary judgment in Fidelity National Financial, Inc., et al. v. U.S. Department of the Treasury, et al., Case No. 3:25-cv-554 (M.D. Fla.).
 
In the suit, Fidelity National Financial and Fidelity National Title Insurance Company challenged a new FinCEN rule requiring reporting of certain all-cash residential real estate transactions. The magistrate recommended that the court rule in favor of the government, uphold the rule, and deny Fidelity’s challenge in its entirety.
 
The new FinCEN rule challenged in the suit would expand and replace FinCEN’s prior temporary, geographically limited Geographic Targeting Orders (GTOs). The magistrate’s recommendation, if adopted, could clear the way for nationwide enforcement of the rule beginning in 2026.
 
Review the Magistrate’s Recommendation »

ICYMI: TDI Adopts Due Dates for Annual Submission of Title Insurance Statistical Data Reports

TLTA | Dec. 11, 2025

TDI announced adoption of the following due dates for annual submission of title insurance statistical reports:

Due Dates for Industry to Submit Data
May 1 - Agents
June 1 - Underwriters

TDI Will Publish Submission Forms / Instructions Two Months Before Due Dates Above
March 1 - Agents
April 1 - Underwriters

Due Dates for TDI to Compile and Publish Annual Data
October 1 - Agents
November 1 - Underwriters

Review the Adoption Order »
Other documents related to TDI's decision making can be found here »

Thank you to TDI and all industry leaders who submitted input
TLTA is grateful that TDI took into account comments made by the industry during this rulemaking. We are thankful too for all the industry members who provided input and worked to get this change made, including providing written comments and comments at the hearing itself. TLTA supports this new structure, which will provide certainty and consistency for the industry.

TDI Publishes Annual Report, Which Includes Data on Title Insurance Companies and References to the Agency's Work Related to Our Industry

TLTA | Dec. 17, 2025

Texas Insurance Code 32.021 requires the Texas Department of Insurance to file an annual report with the governor, the presiding officer of each house of the legislature, State Auditor, Legislative Budget Board, Comptroller of Public Accounts, Legislative Reference Library, and State Library.

Read TDI's Annual Report »