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.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.