What Changed in the 2026 FR/Bar Contract Revision? One Paragraph, and It Is About FinCEN

TALLAHASSEE · October 29, 2026

The 2026 revision to the Florida Realtors/Florida Bar residential contracts changed one paragraph: Section 18.I.(iii), which covers federal FinCEN reporting. Florida Realtors released the updated FR/Bar and AS IS contracts on February 27, 2026. Financing, inspection and post-closing occupancy terms were not part of this update.

The Forms and the Date

The updated forms are the Residential Contract for Sale and Purchase (FloridaRealtors/FloridaBar-7x) and the "AS IS" Residential Contract for Sale and Purchase (FloridaRealtors/FloridaBar-ASIS-7x). Both went live on Form Simplicity, the Florida Realtors forms platform, at 9 a.m. on February 27, 2026.

Florida Realtors posted redlined previews of both contracts. A redline is a copy that marks what was added or removed.

What Section 18.I.(iii) Now Says

FinCEN is the Financial Crimes Enforcement Network, a bureau of the U.S. Treasury. Its Residential Real Estate Rule required a report for certain cash transfers of homes to entities or trusts.

The revised paragraph has two parts. First, it states that certain sales to a buyer that is not an individual, without institutional lender financing, must be reported to FinCEN "beginning March 1, 2026." The parties must give the required information to the Closing Agent by the day before closing. The buyer pays the reporting costs.

Second, it addresses FinCEN Geographic Targeting Orders. If one applies, the buyer must provide information about the buyer and consents to the reporting.

What Happened After the Release

Three weeks after the forms went live, the federal rule behind the new language was struck down. FinCEN reports that on March 19, 2026, the U.S. District Court for the Eastern District of Texas vacated the Residential Real Estate Rule. FinCEN and the Department of Justice have appealed.

FinCEN states that while the order stands, reporting persons "are not required to file Real Estate Reports" and "are not subject to liability if they fail to do so." The contract language remains on the forms.

The Rider That Changed Too

The same release revised Addendum EE, the Qualifying Improvements Rider. It was formerly called the PACE rider. The update reflects amendments to Section 163.081, Florida Statutes, which governs these property-assessed improvement loans.

The Last Full Revision: Version 7 (Rev. 12/24)

The larger changes came in December 2024, when version 7 of both contracts was released. A Miami Realtors forms roadmap lists three changes from the Florida Realtors/Florida Bar Joint Contract Committee:

• Paragraph 9: Defines "Closing Services" and clarifies that each party bears its own Closing Services costs.
• Paragraph 15(a): Removes the provision that let the cooperating broker request half of a deposit retained after a buyer default.
• Paragraph 19: Adds check boxes for Riders FF and GG, which cover buyer broker compensation.

Do Not Confuse It With CRSP

Florida Realtors also publishes its own Contract for Residential Sale and Purchase, known as CRSP. It is a separate form. CRSP17, released March 24, 2025, moved to calendar days for all time periods and added a flood disclosure statement.

What This Means for Your File

Contracts written on the previous form run on the previous form's terms. You don't retroactively apply the new one. For new files, confirm the footer reads 7x or ASIS-7x before the offer goes out. Note that Section 18.I.(iii) still describes a reporting rule that is on hold, so ask the closing agent how they are handling it. HTC updates its internal contract review template when forms change. Monday morning, pull every open file with an entity or trust buyer paying cash and confirm the closing agent's FinCEN position in writing.

Frequently Asked Questions

Do I need the new form for a contract signed before February 27, 2026?

No. A contract written on the previous form runs on that form's terms. Use the 7x or ASIS-7x forms for new offers, and check the footer before the offer goes out.

Do closing agents still have to file FinCEN Real Estate Reports?

Not while the court order stands. FinCEN says that since the March 19, 2026 order vacating the rule, reporting persons are not required to file and face no liability for not filing. FinCEN and the Department of Justice have appealed, so ask the closing agent how they are handling it.

Is CRSP the same as the FR/Bar contract?

No. CRSP is Florida Realtors' own Contract for Residential Sale and Purchase, separate from the joint Florida Realtors/Florida Bar contracts. CRSP17, released March 24, 2025, moved to calendar days for all time periods and added a flood disclosure statement.

Did anything else change in the February 2026 release?

Yes. Addendum EE, the Qualifying Improvements Rider (formerly the PACE rider), was revised to reflect amendments to Section 163.081, Florida Statutes.