October 27, 2022

FinCEN Renews 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 also expanded the GTOs to include two new counties in Texas.

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. The renewed GTOs will be effective from October 27, 2022 until April 24, 2023.

Additionally, FinCEN expanded the GTOs to include counties encompassing Houston and Laredo, Texas. The effective period of the GTOs in these newly added areas begins on November 25, 2022. 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.

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