NAELA concurs in great part with the American Bar Association’s April 8, 2024, comments opposing any proposed rules which would require lawyers to disclose information relating to the legal representation of their clients in non-financed residential real estate transfers as contrary to professional conduct rules, attorney-client privilege, and the ABA Model Rules, many of which have been adopted by numerous states. NAELA agrees that the proposed rule-making is overbroad, superfluous, and unnecessary; lacks clear Congressional intent; and exceeds FinCEN’s regulatory authority, thus violating the Administrative Procedure Act. Read NAELA’s full letter
here.