FinCEN has issued Geographic Targeting Orders (“GTOs”) requiring certain U.S. title insurance companies to identify the natural persons behind companies used to pay all cash for high-end residential real estate in New York City, Broward, Palm Beach and Miami-Dade Counties in Florida, Bexar County, Texas, Los Angeles, San Diego, San Francisco, San Mateo and Santa Clara Counties in California, in the City and County of Honolulu in Hawaii, and, effective November 17, 2018, Tarrant and Dallas Counties in Texas, Clark County in Nevada, King County in Washington, Suffolk and Middlesex Counties in Massachusetts, and Cook County in Illinois. The GTO issued on November 15, 2018 reduced the monetary threshold for the purchase of residential real property for all of the affected jurisdictions to $300,000 or more and included purchases made with virtual currencies.
These GTOs were renewed by FinCEN on November 8, 2019. The GTO just issued is effective November 12, 2019 and ends on May 9, 2020. It amends the definition of a “Legal Entity”; reporting will not be required for purchases made by “a business whose common stock or analogous equity interests are listed on a securities exchange regulated by the Securities Exchange Commission (‘SEC”) or a self-regulated organization registered with the SEC, or an entity owned by such a business.”
FinCEN’s News Release, the new GTO and “Frequently Answered Questions” can be obtained at the following links:
News Release: https://www.fincen.gov/news/news-releases/fincen-reissues-real-estate-geographic-targeting-orders-12-metropolitan-areas-0
