U.S. Treasury Order Affects Title Companies in Bexar County
Requirements went into effect Aug. 28, 2016 and were updated on Aug. 22, 2017
In an effort to identify money-laundering schemes, the U.S. Treasury Department Financial Crimes Enforcement Network (FinCEN) has issued an updated Geographic Targeting Order (GTO)
requiring all title insurance companies to identify the names of individuals involved in corporations, LLCs and other legal entities that make all-cash purchases for high-end residential real estate in Bexar County. This GTO also affects the Miami-Dade area and nearby counties, all five New York City boroughs, several California counties and the city and county of Honolulu, Hawaii. The new effective date is 180 days starting on Sept. 22, 2017. All affected title companies should have received their orders.
TLTA is currently reviewing how the Treasury Department’s approach will affect TLTA members and private property owners in Texas and will continue to provide more details about compliance as we learn them. Note that the threshold in Bexar County is residential cash deals purchased by corporate entities above $500,000.
GTO Details (updated Aug. 22, 2017)
FinCEN Geographic Targeting Order (GTO) Advisory
FinCEN FAQs on GTO
FinCEN Press Release: Aug. 22, 2017
GTO Monetary Thresholds Table
ALTA Webpage on FinCEN Resources, Webinars, Advocacy and Regulations
ALTA FAQ for August 2016 GTO
ALTA Covered Transaction Determination Form
ALTA Information Collection Form
ALTA-TLTA FenCEN Webinar Recording
ALTA-TLTA FinCEN Webinar Handout
ALTA Statement on FinCEN Orders
FinCEN Geographic Targeting Order: What You Need to Know Before Closing a Deal in Bexar County
Steve Gottheim, Senior Counsel, ALTA
Lawrence Scheinert, Section Chief, Office of Special Measures, FinCEN
All title insurance agents and underwriters in Bexar County or who are involved in handling transactions in Bexar County are urged to participate in this informative webinar.
(No CE credit available)
Note: This is the recorded webinar from Aug. 18, 2016.
*If this is the first time you have participated in a webinar hosted by the GoToWebinar service, there is a small piece of software that will be downloaded to your computer.