For title underwriting counsel, closing compliance managers and escrow officers · ROAD Act Purchase Monitor · built 2026-11-06 · data f648182df9ae · ban effective January 7, 2027 · comments on TREAS-DO-2026-0529 close November 23, 2026

Your desk will be asked: is this buyer a 350-home investor? Answer it on the order.

If you write the underwriting bulletin, run closing compliance or sign off an entity-buyer file, this lands on you first. From January 7, 2027, a firm that controls 350 or more single-family homes, alone or in concert, may not buy another one unless the purchase is excepted. The civil penalty is up to the greater of $1 million or three times the price, per purchase. Treasury says reliable data on who is covered does not exist yet. This monitor answers it from the county records: 43 investor groups hold 166,797 homes in 17 large rental counties under 2,325 legal names. 19 of those groups have no single entity at 350, so a title search on the vesting name alone would clear them.

Try the prefilled order: SN DFW LLC holds 84 homes under its own name, and no exact, name-root or fuzzy name search ties it to 350. It shares Scottsdale mailbox 303 with the rest of the SN family: 1,146 homes in coverage under 27 names.

Backfile test: your own orders

Screen a title order

The check a title underwriter runs when the order opens, before the deed records. It resolves the buyer through names, Texas registry filings, mailing addresses and name roots to its control group, reads the property and seller from the roll, tests the exceptions the records can speak to, and returns a stored screening id with the full evidence trail. API: POST /api/road-monitor/screen (one order or 500 at a time, JSON or CSV, sample file). MCP: road_screen_purchase.

What a name search misses

Purchases by month

Last recorded deed per parcel, entity-owned single-family homes, surveillance counties only. Recent months fill in as counties record. Bars: market purchases by covered investor groups with same-day bulk clusters removed (solid), and all builder / iBuyer deeds (outline).

Covered groups

Builders, iBuyers and groups under review

Watchlist: 250 to 349 homes in coverage

Under the line in these 17 counties. Holdings elsewhere count toward 350, so these are the groups most likely covered nationally.

Agency view: the case queue

Every deed since July 11, 2026 into a covered group, lender and servicer entities removed: market purchases with no build-to-rent signal first, same-day bulk clusters (likely affiliate restructurings) last. None of these is a violation, because the ban starts January 7, 2027. From that date a row like these needs an excepted-purchase file, or a referral. 1,556 rows; the first 40 below. Full queue: GET /api/road-monitor?cases=1&limit=500, MCP road_purchase_stream.

Registered entities with no homes yet

Texas-registered entities whose principal office is an office a covered group uses for its homes, that carry the group's own name root, and that own no home on any roll in coverage yet. Because they carry the group's name, a name search catches these too; the screen adds the registry record and the shared office as evidence. Almost all were chartered before enactment. 85 today; the newest 25:

Coverage

Method and limits

• graph: Owner names on 17 county rolls, linked by shared owner mailing address (MAIL), Texas franchise registry principal office (PRIN), distinctive name root within a ZIP3 (ROOT), SEC Exhibit 21 (SEC) and curated parent families (PARENT); registered-agent and tax-service hub addresses are blocked.
• status: COVERED: investor group at 350+ homes in coverage (also 350+ without lender/servicer entities). BUILDER_IBUYER: 350+ but coverage turns on the 'engaged in the business' test (NPRM 36.15). REVIEW: 350+ on a name-based merge not yet confirmed, or under 350 once lender entities are removed. EXCLUDED: IRA custodian / HOA. BELOW_THRESHOLD: 250-349.
• stream: Last recorded sale date per parcel on each county roll, for entity-owned single-family homes whose owner resolves to a 350+ group. Last sale only, so a home bought twice counts once (a floor); some deeds are transfers between affiliates. Counted only in counties whose roll carries 1,000+ deeds of any buyer dated after July 11 2026. Deeds in same-buyer, same-day clusters of 5+ are flagged BULK_SAME_DAY_TRANSFER and reported apart from market purchases: they are mostly securitization and affiliate restructurings, which the NPRM treats as in compliance (sec. 1001(b)(2)(B)). 1st-of-month dates are flagged as likely roll-date artifacts.
• name_search: A group counts as hidden from name search only if exact name, name root (graph normalizer) and a fuzzy prefix search on its largest entity's name (spaces and punctuation removed, single letters joined) each find under 350 of its homes.
• vehicles: Texas franchise taxpayers whose principal office (normalized) is an address 80%+ used by one covered group's homes or registry filings, excluding addresses shared by 150+ taxpayers statewide, and only when the new entity also carries the group's name root, or one of the group's own distinctive name tokens plus a real-estate word.
• exceptions: Signals only, not determinations: BULK_SAME_DAY_TRANSFER (5+ deeds to one buyer on one date: likely restructuring, sec. 1001(b)(2)(B)), ROLL_DATE_FIRST_OF_MONTH (date may be a roll artifact), NEW_CONSTRUCTION (year built within a year of the sale: build-to-rent 36.5 may apply), BTR_COMMUNITY (5+ same-group homes on one street with one build year), LENDER_SERVICER_ENTITY (loss mitigation 36.10; kept out of counts).

• Counts cover 17 counties only and are a floor for every group's national total.
• A shared mailing address is evidence of shared management or tax handling, not proof of investment control.
• GA Cobb, DeKalb and Fulton, TN Shelby and TX Bexar rolls carry no usable deed dates, so purchases there are screened at order time but not in the stream.
• The roll does not carry the seller, so seller-side exceptions (36.11) are checked at screening time from the seller's own record.
• Purchases before January 7 2027 are not violations: the ban applies to purchases on or after that date. The stream shows the volume a screen will face, not past violations.
• Entity-link precision and recall have not been measured on a labeled sample yet. Groups within 25 homes of 350 can flip on one weak link.

For a whole desk, or a federal office

Path after the free test: a Compliance Audit at $25,000; Audit + Watch at $75,000 a year; a 90-day pilot at $90,000 credited to year one; then underwriter, investor-desk and agency licenses. Statute: 21st Century ROAD to Housing Act sec. 1001, 42 U.S.C. 19521. Proposed rule: Treasury NPRM 31 CFR Part 36, RIN 1505-AC96, docket TREAS-DO-2026-0529, 91 FR 66799 (Oct 23 2026). Penalty: up to the greater of $1,000,000 or 3x the purchase price per purchase (sec. 1001(d)(1); NPRM 36.17). Enforcement: Treasury, or DOJ at Treasury's request (sec. 1001(d)(1)). Tensorust LLC is not affiliated with the Department of the Treasury. Screening results are evidence for the title file and counsel, not legal advice. Agency and underwriter licenses: mattbusel@tensorust.com.

Rankings: Groups ranked by homes and deeds since enactment. Your own buyer, closing or parcel list measured in 5 business days: 5-day sprint.