September 25, 2025

In This Issue:

TLTA Submits Recommendation to TREC's Broker Lawyer Committee As They Consider Standard Contract Change Related to New FinCEN Reporting Rule
CORRECTED: New FIRPTA Payment Requirement On Hold for Now
FedNow Will Raise Transaction Limit to $10 Million Effective Nov. 1
TDI Compliance Reminder: Agent's TS-1 Due Next Week

TLTA Submits Recommendation to TREC's Broker Lawyer Committee As They Consider Standard Contract Change Related to New FinCEN Reporting Rule

TLTA | Sept. 24, 2025

The Texas Real Estate Commission's Broker Lawyer Committee is considering changes to the residential real estate standard contract related to the U.S. Department of Treasury Financial Crimes Enforcement Network (FinCEN) Final Residential Real Estate Reporting Rule, which will be effective Dec. 1.

Review TLTA's Recommendation »

TLTA Editor's Note: If you are unfamiliar with the new FinCEN residential reporting rule that will be effective Dec. 1, watch TLTA's special, 2-hour compliance clinic. These new federal reporting obligations are extensive, and you should start preparing now to ensure you are compliant.

CORRECTED: New FIRPTA Payment Requirement On Hold for Now

TLTA | Sept. 25, 2025

Implementation of Presidential Executive Order 14247, requiring electronic payments for all federal disbursements and receipts, has been delayed. See new IRS guidance issued Tuesday:

https://www.irs.gov/newsroom/irs-to-phase-out-paper-tax-refund-checks-starting-with-individual-taxpayers

Earlier guidance that title agents submitting FIRPTA withholdings for buyers would have to do so via electronic payment only beginning on Sept. 30 is no longer applicable. Implementation of this electronic payment requirement is on hold for now, with the IRS offering the following look ahead:

"The IRS will provide detailed guidance for the 2025 tax returns before the 2026 filing season begins. Until further notice, taxpayers are to continue using the current forms and procedures, including those who are filing their 2024 returns on an extension due before December 31, 2025."

TLTA’s Editor’s Note: This information is being provided by TLTA for educational and reference purposes only and should not be construed as legal, financial or business advice from or on behalf of TLTA. You should consult your own legal counsel and subject-matter experts to ensure that any policies adopted or actions taken meet the requirements unique to your company.

FedNow Will Raise Transaction Limit to $10 Million Effective Nov. 1

Federal Reserve | Sept. 16, 2025

Federal Reserve Financial Services (FRFS) will increase the FedNow Service network transaction limit from $1 million to $10 million in response to growing commercial demand, effective November 2025. The increased limit will enable financial institutions and businesses to support higher-value use cases and reflects an increasing need for speed and certainty in the modern payments ecosystem.

Learn more »

Compliance Reminder: Agent's TS-1 Due Next Week

TLTA | Sept. 1, 2025

Form T-S1, Title Agent's Unencumbered Assets Certification, must be submitted annually to TDI between Sept. 1 and Sept. 30 of each year.

Please submit your TS-1 by Monday, Sept. 30 to [email protected]