On July 27, 2016 the Financial Crimes Enforcement Network (FinCEN), a bureau of the US Department of Treasury, issued Geographic Targeting Orders (GTO) that will require all US title companies to report and identify the names of all cash purchases of residential real estate by corporate entities in six major metropolitan counties.
FinCEN is working to uncover all-cash purchases from individuals that may be attempting to hide their assets and identity by purchasing residential properties. This includes natural persons with 25% or greater ownership interest in a legal entity, or all of the names of an LLC, including any subsidiaries and agents of (“Covered Business”).
Frequently Asked Questions:
￼WHEN ARE THE EFFECTIVE DATES?
The reporting will run from August 28, 2016 to February 23, 2017.
WHAT IS A GEOGRAPHIC TARGETING ORDER?
Under the Bank Secrecy Act (BSA), the director of FinCEN can issue orders which require additional record keeping and reporting requirements on domestic financial institutions in a specific geographic areas (“Covered Transactions”) that involve transactions using certain amounts of United States currency or monetary instruments. Orders such as these can be in effect for up to 180 days. See 31 USC § 5326(a); CFR § 1010.370.
HOW DO WE COMPLY WITH THE GTO?
If the transaction is a Covered Transaction, Ticor will submit the “ALTA Information Collection Form” signed by the buyer, and file a completed FinCEN Form 8300 pursuant to the directions contained in the GTO.