April 18, 2024
In This Issue:
- TLTA Submitted Comments to FinCEN on Their Proposed New Reporting Requirements for Title Agents
- FinCEN Renews Real Estate Geographic Targeting Order
- ALEC: A Largely Unnoticed Part of the State of the Union Address Threatens to Undermine State Regulatory Authority and State Sovereignty
- ICYMI: Reportably, CFPB May Consider Ban on Charging Buyers for Lender’s Title Policy
- Emails Claiming to Sell TLTA Contact Database Are a Scam – Don’t Click or Reply
TLTA Submitted Comments to FinCEN on Their Proposed New Reporting Requirements for Title Agents
TLTA | April 18, 2024
The comment period for the notice of proposed rulemaking announced by FinCEN on February 7, 2024, has ended. TLTA submitted comments to FinCEN on behalf of the Texas title insurance industry.
A huge thank you to all who responded to our call to action and took the time to submit your personal comments. We cannot emphasize enough the importance of FinCEN hearing your individual feedback about how this proposal will impact your business and customers. We are very grateful for your engagement in this process.
Review TLTA's comments »
Background
On Feb. 7 FinCEN issued a
notice of proposed rulemaking on new reporting and compliance requirements that would have a significant impact on you and your business when handling cash transactions.
What Happens Next?
FinCEN will have to analyze all the comments they received and determine how to incorporate them in any final rule they adopt. We do not have an estimated timeline on that process, but rest assured, we’ll keep you informed throughout.
Learn more »
Questions?
If you have questions, please send them to
Aaron Day or call Aaron at 512.810.8800, thank you.
FinCEN Renews Real Estate Geographic Targeting Orders
U.S. Treasury | April 17, 2024
The Financial Crimes Enforcement Network (FinCEN) announced the renewal of its Geographic Targeting Orders (GTOs) that require U.S. title insurance companies to identify the natural persons behind shell companies used in non-financed purchases of residential real estate. The terms of the GTOs are effective beginning April 19, 2024, and ending on October 15, 2024.
The following Texas counties continue to be included in GTO:
Bexar, Dallas, Harris, Montgomery, Tarrant, Travis, Webb
Learn More »
ALEC: A Largely Unnoticed Part of the State of the Union Address Threatens to Undermine State Regulatory Authority and State Sovereignty
American Legislative Exchange Council | April 8, 2024
.In March, President Biden made a last-minute change to his State of the Union Address (SOTU), adding a commitment to eliminate title insurance fees on certain federally backed mortgages. Just hours before the address, the Federal Housing Finance Agency (FHFA) announced plans to launch a pilot program to advance the same idea overriding a decision to halt a similar project due to its associated risks and bipartisan congressional opposition in 2023. The FHFA proposal was issued without the transparency and comment period that typically precedes significant policy changes. If implemented, the President’s pledge threatens property rights, makes homeownership riskier and undermines state law governing title insurance. In other words, it is inconsistent with ALEC’s core principle of federalism.
Read More »
TLTA Editor's Note: In case you missed it, there's a page on TLTA's site dedicated to news, Congressional response and background info related to the FHFA: Fannnie/Freddie Title Insurance Waiver Pilot Project discussed in this commentary from ALEC above.
ALTA and TLTA are working non-stop to ensure that state and federal legislators are aware of the ramifications of this new policy
ICYMI: Reportedly, CFPB May Consider Ban on Charging Buyers for Lender’s Title Policy
TLTA | April 12, 2024
Charging home buyers for title insurance is a long-standing industry practice intended to protect lenders. A Bloomberg report initially broke the news that the CFPB might soon issue a broad request for information on closing costs – including title insurance.
CFPB has not confirmed this report.
Statement from a CFPB spokesperson
“The CFPB is looking carefully at closing costs and fees consumers may encounter throughout the mortgage process. We are working with agencies across the government to foster greater competition in the mortgage market and help Americans save money when purchasing or refinancing a home.”
Learn More »
TLTA Editor's Note: As we've been reporting, CFPB has been engaged in a "Junk Fee" initiative for many months. Two weeks ago in Dateline we shared this news, which details the ways in which this CFPB intiative relates to mortgage closing costs. If you want to take a deeper dive into this subject, TLTA built a special page where we are collecting information related to this issue: CFPB “Junk Fee” Initiative.
We should remain aware of the apparent connection between these federal level developments. In case you missed it, there's a page on TLTA's site dedicated to news, Congressional response and background info related to the FHFA: Fannnie/Freddie Title Insurance Waiver Pilot Project that was announced during the State of the Union address last month.
Emails Claiming to Sell TLTA Contact Database Are a Scam – Don’t Click or Reply
TLTA | April 18, 2024
Some TLTA members have reported receiving emails that claim to be selling TLTA's contacts database (here’s an example):
These emails are a scam. Any links they contain should not be clicked, as they likely open the door to malicious software.
Additionally, these emails should not be replied to. TLTA does not sell members’ contact information, and any info third-parties claim to be TLTA-related is fraudulent.
If you are in the market for B2B marketing help, research vendors by first talking to other industry professionals. Responding to a cold call via email purporting to deliver something that seems too good to be true should be avoided.
As always, if you see something strange that claims to be associated with TLTA, please share it with us, and we’ll be happy to review and advise you regarding its validity.