FinCEN, Geographic Targeting Order, Title Company

New Requirements for Miami-Dade, Broward and Palm Beach Counties Real Estate Transactions

fincenThe U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has issued a new Geographic Targeting Order (GTO) which supplements and supersedes all previous orders. The order directs all title insurance companies and its agents to report information about certain residential real estate transactions in Florida.

As anticipated the GTO has expanded the types of real estate transactions that need to be reported. While previously exempted, Covered Transactions now includes those where funds are provided via wire transfers.

These covered transactions include any real estate transactions that meet all the criteria noted below.

1. The transaction involves residential real estate in Miami-Dade, Broward and Palm Beach Counties; and

2. The purchase price exceeds $1 million; and

3. The purchaser is a corporation, Limited Liability Company (LLC), partnership, or other similar legal entity. (The definition does not include natural persons or trusts.); and

4. The purchaser purchases the real estate without a bank loan or other similar form of institutional financing; and

5. The purchaser pays any part of the purchase price using currency, cashier’s checks, certified checks, traveler’s checks, money orders, business or personal checks or wire fund transfers or payments.

If a transaction meets all these required elements, then settlement agents must complete FinCEN Form 8300 and forward it to Old Republic Title for filing. These changes take effect on September 22, 2017 and continue through March 20, 2018 (unless extended by FinCEN). Agents must provide all the information required under the GTO on that form. This includes identifying information for each natural person owning at least 25% or more of the business entity purchasing the property.

For more information contact New Frontier Title

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