26 Aug FinCEN Updates Geographical Targeting Order
 On July 26, 2016, the Financial Crimes Enforcement Network (“FinCEN”), a bureau of the United States Department of Treasury, issued a Geographical Targeting Order (“GTO”) requiring title insurers, their subsidiaries and agents, to report certain information in connection with the purchase of 1-4 unit residential real properties in Covered Transactions.
A “Covered Transaction” is an all-cash transaction in which the property is being purchased by a limited liability company, corporation, partnership or a similar legal or business entity, and the purchase price is $2,000,000 or more (for properties in the counties of San Diego, Los Angeles, San Francisco, San Mateo or Santa Clara, California). If a property is being purchased in a Covered Transaction that meets these criteria, the proposed insured purchaser must provide all information necessary for the Title Company to complete IRS form 8300. |
| What are Covered Transactions?
* The property being purchased is 1-4 unit residential property; * The property is located in any of the designated counties of California * The sales price meets the designated threshold amount; * The purchaser is a legal entity (i.e., a corporation, LLC, partnership or similar business entity); * The property is purchased without a loan or similar form of external financing; and * Any portion of the purchase price is paid using currency, cashier’s check, certified check, traveler’s check, money order, personal check or business check. |
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To satisfy this requirement, we may need to obtain additional information from other parties involved in the transaction. For more information, please visit the following links: |
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