Requirements Go Into Effect Aug. 28, 2016
In an effort to identify money-laundering schemes, the U.S. Treasury Department Financial Crimes Enforcement Network (FinCEN) has issued a 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 and several California counties. The effective date is 180 days starting on Aug. 28, 2016.
TLTA is currently reviewing how the Treasury Department’s approach will affect TLTA members and private property owners in Texas and will provide more details about compliance as we learn them. In the meantime, all affected title companies should have received their orders. Note that the threshold in Bexar County is residential cash deals purchased by corporate entities above $500,000.
ALTA has issued a press release and created several resources for those affected by the FinCEN GTO, including FAQs. These resources will be updated in the coming days to reflect additional information about the Bexar County order.
You can also review a sample GTO online.
Again, TLTA will continue to keep members informed about this development. If you have questions, please contact Aaron Day, Director of Government Affairs and Counsel, at 512.879.2881 or  
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Texas Land Title Association, 1717 W. 6th St., Suite 120, Austin, TX, 78703
Phone 512.472.6593 | Fax: 512.472.5931