Arizona Real Estate | Pima County • Updated Jan 12, 2026

All-Cash Closings in Arizona Aren’t Always Fast

What Tucson & Pima County agents need to know for 2026 and beyond

Quick Answer: Cash removes the lender—not the laws. Federal reporting (FinCEN), liens, FIRPTA, OFAC screening, court authority, wire timing, and local compliance can delay or stop an all-cash closing in Arizona.

In this post:
  1. The myth: “cash means fast”
  2. FinCEN’s 2026 rule: what’s changing
  3. What’s NOT an Arizona issue (GTOs)
  4. Government-related delays that still hit cash deals
  5. The 5 questions that prevent most delays
  6. Internal resources for agents
  7. Primary sources

The Myth: “Cash Means Fast”

When a client says “it’s cash,” they usually mean “there’s no lender.” That helps—but it does not remove the real-world friction points that live in title, taxes, courts, compliance, and bank wiring.

Cash removes underwriting. It doesn’t remove: tax liens, municipal liens, court authority, federal reporting, sanctions screening, or the operational reality of moving large sums through regulated banks.

The New Federal Layer Agents Must Understand (Effective March 1, 2026)

FinCEN’s Residential Real Estate Rule (RRE Rule)

FinCEN (U.S. Treasury) finalized a nationwide rule requiring reporting for certain non-financed residential transfers—often described as “cash deals”—when the buyer is a legal entity or trust (e.g., an LLC, corporation, or many trusts).

Why this matters in practice: escrow/title may need beneficial ownership and entity documentation. If the parties discover that late, it can create documentation churn—and missed timelines.

Important timing note: FinCEN issued exemptive relief delaying the reporting requirement until March 1, 2026. Closings prior to that date are exempt from the filing requirement.

Agent tip: You don’t file the report—but you can prevent delays by spotting entity/trust buyers early and getting escrow what they need sooner rather than later.

What Is NOT an Arizona Issue (But Agents Hear About)

Geographic Targeting Orders (GTOs)

FinCEN’s Geographic Targeting Orders apply enhanced reporting to specific counties in other states. Arizona and Pima County are not currently listed in the GTO coverage. GTOs are separate from the nationwide RRE rule taking effect in 2026.

Other Government-Related Issues That Delay Cash Closings in Arizona

1) Tax Liens & Government Liens

Cash does not erase liens. Federal, state, and municipal liens typically must be satisfied, released, or otherwise resolved before title can insure. In Pima County, delays often come from payoff timing and release/recording logistics.

2) Court Authority & Legal Capacity

Probate, conservatorships, divorce orders, and bankruptcy involvement can require court authority before a valid conveyance can occur. Cash doesn’t bypass court jurisdiction.

3) FIRPTA (Foreign Seller Withholding)

If a seller is a foreign person, federal law may require FIRPTA withholding and associated forms/processing—an easy surprise that can slow timelines even in a “simple” cash deal.

4) OFAC / Sanctions Screening

Title and escrow providers commonly run sanctions screening. Potential matches can pause a closing while the parties are cleared; in rare cases, a transaction may be prohibited.

5) Funds Movement (Wires) & Bank Verification

Large wires can be delayed by bank verification, fraud controls, cutoff times, and last-minute changes—especially around month-end. A cash buyer can be fully legitimate and still hit “timing friction.”

6) Local Compliance: Permits, Code, and Recording

Open permits, code enforcement issues, or unpermitted work can trigger negotiations, cure periods, or insurer concerns. Recorder timing and end-of-month volume can create operational delays.

The 5 Questions That Prevent Most Cash-Closing Delays

  1. Buyer structure: Is the buyer an individual, LLC, or trust?
  2. Foreign parties: Is any party foreign (seller or buyer)?
  3. Liens/court issues: Any tax liens, judgments, probate, or bankruptcy?
  4. Funds readiness: When will funds be wire-ready—and what bank is involved?
  5. Escrow requirements: What does escrow/title want up front to keep this smooth?

Internal Resources for Agents (Move Kit)

If you’re building your systems (or switching brokerages), these resources help you stay compliant and organized:

Want a simple “Cash Deal Intake” checklist? Message me and I’ll send the one we use to prevent last-minute delays.

Or explore the Move Kit Hub: Start here.

Primary Sources (External Links)

Disclaimer: This post is informational and not legal or tax advice. For transaction-specific compliance questions, consult escrow/title and appropriate counsel.