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CLTA FinCEN Resource Center



U.S. Treasury Order Affects Title Companies Operating in Five California Counties

Requirements go into effect Aug. 28, 2016

In an effort to identify money-laundering schemes, the U.S. Treasury Department Financial Crimes Enforcement Network (FinCEN) has issued a Geographic Targeting Order (GTO) requiring all title insurance companies to identify the names of individuals involved in corporations, LLCs and other legal entities that make all-cash purchases for high-end residential real estate ($2M and above) in five California counties: Los Angeles, San Diego, San Francisco, San Mateo, and Santa Clara. The effective date is 180 days starting on Aug. 28, 2016. All affected title companies should have received their orders.

Update 8/29/16: FinCEN officials have issued a verbal statement indicating that trusts of any kind fall outside the scope of the newly-issued Geographical Targeting Orders. We expect a formal confirmation of this statement in writing soon, and will keep membership apprised of any new information we receive. As always, we strongly encourage individuals to consult with their title insurer if there is any question as to whether a transaction warrants reporting under the GTO.

FinCEN Forms

Developed in partnership with the American Land Title Association, individuals can use these fillable .PDF questionnaire forms to determine whether a transaction falls under reporting obligations and Information Collection Form:

Real Estate Professional FinCEN Infographic

Intended for title companies to distribute to real estate professionals with which they are in contact, this infographic quickly breaks down the basics of the FinCEN Geographical Targeting Orders: CLTA FinCEN Real Estate GTO Infographic.

Recorded Webinar:  re: FinCEN Order

CLTA, with the help of ALTA, recorded a webinar which was presented on August 19th.  The webinar outlines the order and how to comply. All title insurance agents and underwriters in San Diego, Los Angeles, San Francisco, San Mateo and Santa Clara Counties, or anyone who is involved in handling transactions in these counties, are urged to view this recorded webinar.  

NOTE: The above presentation is meant for informational purposes only and the statements and opinions provided are not those of CLTA or its member companies. CLTA strongly recommends that underwritten title companies, independent escrow companies and real estate professionals consult directly with the title insurance companies with which they do business to discuss the title insurer’s precise expectations and protocols associated with FinCEN reporting.

ALTA Resources 

California Land Title Association

1215 K Street #1816 Sacramento, CA 95814-3905
Email:  |  Phone: 916-444-2647  |   Fax: 916-444-2851