ARTICLE
20 November 2019

FinCEN Reissues Geographic Targeting Order For 2019-2020

CW
Cadwalader, Wickersham & Taft LLP

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Cadwalader, established in 1792, serves a diverse client base, including many of the world's leading financial institutions, funds and corporations. With offices in the United States and Europe, Cadwalader offers legal representation in antitrust, banking, corporate finance, corporate governance, executive compensation, financial restructuring, intellectual property, litigation, mergers and acquisitions, private equity, private wealth, real estate, regulation, securitization, structured finance, tax and white collar defense.
FinCEN renewed a Geographic Targeting Order ("GTO") requiring title insurance companies to collect and report beneficial ownership information for certain real estate purchases.
United States Finance and Banking
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FinCEN renewed a Geographic Targeting Order ("GTO") requiring title insurance companies to collect and report beneficial ownership information for certain real estate purchases. The Order is effective from November 12, 2019 to May 9, 2020.

According to FinCEN, the reissued GTO is similar to the May 2019 GTO but with one change: title insurance companies no longer will be required to report purchases made by entities that are U.S. publicly traded companies. As previously covered, the reissued GTO applies when a legal entity purchases residential real estate that:

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

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