U.S. Treasury Order Affects Title Companies in Bexar County

Requirements go into effect Aug. 28, 2016 and were renewed on Feb. 23, 2017

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. 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 Feb. 23, 2017)

FinCEN Geographic Targeting Order (GTO) News Release
Sample GTO
FinCEN FAQ GTO
GTO Monetary Thresholds Table
Form 8300

Resources

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 Advocacy

ALTA Statement on FinCEN Orders

Free Webinar

FinCEN Geographic Targeting Order: What You Need to Know Before Closing a Deal in Bexar County 

Presented by: 
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.
This information is being provided by TLTA for educational and reference purposes only, and is not intended to represent the only approach to any particular issue. This information should not be construed as legal, financial or business advice from or on behalf of TLTA, and users should consult their own legal counsel and subject-matter experts to ensure that any policies adopted or actions taken meet the requirements unique to their company.