May 15, 2019

FinCEN Renews Real Estate GTO for 12 Metropolitan Areas

The FinCEN renewed a Geographic Targeting Order ("GTO") requiring title insurance companies to collect and report beneficial ownership information for certain real estate purchases.

The reissued GTO applies when a legal entity purchases residential real estate that:

  • is in one of the specified areas (e.g., Boston, Chicago, Dallas-Fort Worth, Honolulu, Las Vegas, Los Angeles, Miami, New York City, San Antonio, San Diego, San Francisco and Seattle);

  • sells for at least $300,000;

  • does not involve a bank loan or similar external financing; and

  • is purchased, at least in part, with currency or a cashier's check, certified check, traveler's check, personal check, business check, money order, funds transfer or virtual currency.

The GTO will be effective for real estate transactions occurring from May 16, 2019 to November 11, 2019.

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