All-Cash Residential Real Estate Transactions – New Government Oversight Rules (Update)

By | August 17, 2016

Summary – ‘On July 17th, 2016, the Financial Crimes Enforcement Network (FinCEN), a bureau of the U. S. Department of Treasury, issued Geographic Targeting Orders to all title companies. The orders impose temporary new data collection and reporting requirements for all cash purchases of residential real estate by corporate entities in certain counties.

We continue in our effort to provide Hallmark Abstract Service clients and blog readers relevant and up-to-date information concerning changes and/or new rules that govern residential real estate transactions in New York and elsewhere around the country. These were two recent articles:

New York City Real Estate, Government Edicts And The Inevitable Unintended Consequences!

FinCEN Disclosures (Geographic Targeting Orders) For Cash Real Estate Transactions Expanded!

There are, however, additional explanations, tools and resources that have been made available by ALTA (American Land Title Association) that explain in greater detail the US Treasury’s temporary requirements governing all-cash residential real estate transactions in certain jurisdictions around the country.

Compliance Information for US Treasury FinCEN Geographic Targeting Order (GTO) of July 2017

(The following information was provided by the American Land Title Association.)

The resources available are:

On July 17th, 2016, the Financial Crimes Enforcement Network (FinCEN), a bureau of the U. S. Department of Treasury, issued Geographic Targeting Orders to all title companies. The orders impose temporary new data collection and reporting requirements for all cash purchases of residential real estate by corporate entities in certain counties. Under the Order, title companies, including any subsidiaries and agents of (“Covered Business”), must report the names of all natural persons with 25% or greater ownership interest in a legal entity, or the names of all members of an LLC. This reporting requirement runs from August 28, 2016 through February 23, 2017.

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