FinCEN Renews and Expands Geographic Targeting Orders

FinCEN renewed its Geographic Targeting Orders ("GTOs") requiring U.S. title insurance companies to collect and report beneficial ownership information for certain residential real estate purchases.

FinCEN renewed the GTOs in Boston, Chicago, Dallas-Fort Worth, Las Vegas, Los Angeles, Miami, New York City, San Antonio, San Diego, San Francisco, Seattle, the District of Columbia, Northern Virginia, Maryland, the City and County of Baltimore, the County of Fairfield, Connecticut and the Hawaiian islands of Honolulu, Maui, Hawaii and Kauai.

FinCEN expanded the GTOs to include (i) Litchfield County in Connecticut and (ii) Adams, Arapahoe, Clear Creek, Denver, Douglas, Eagle, Elbert, El Paso, Fremont, Jefferson, Mesa, Pitkin, Pueblo, and Summit counties in Colorado. The effective period for the GTOs in these newly added areas begins on May 24, 2023. The purchase amount threshold remains unchanged at $300,000, except for in the City and County of Baltimore, where the purchase threshold is $50,000.