FinCEN Reissues Real Estate Geographic Targeting Orders
Friday, November 16, 2018
November 16, 2018
On November 15th the Financial Crimes Enforcement Network (FinCEN) announced the issuance of revised Geographic Targeting Orders (GTOs). The GTOS require that U.S. title insurance companies identify the individual representing the Legal Entity purchaser as well as all natural persons behind those legal entities owning 25% or more equity interest when that Legal Entity is purchasing residential real estate without institutional lender/bank funding. The purchase amount threshold, which previously varied by city, is now set at $300,000 for each covered metropolitan area. FinCEN requires reporting on these covered purchases where any portion of the funds, including earnest money deposit, is paid using currency, cashier’s check, wire transfers, money orders, or personal or business checks. The California counties covered by the new GTOs did not change, and continue to include: San Diego, Los Angeles, San Francisco, San Mateo and Santa Clara. The terms of the GTOs are effective beginning November 17, 2018 and ending on May 15, 2019.
The full News Release from FinCEN is available here.