On July 17th, 2016, the Financial Crimes Enforcement Network (FinCEN), a bureau of the U. S. Department of Treasury, issued Geographic Targeting Orders to all title companies. The orders impose temporary new data collection and reporting requirements for all cash purchases of residential real estate by corporate entities in certain counties. Under the Order, title companies, including any subsidiaries and agents of (“Covered Business”), must report the names of all natural persons with 25% or greater ownership interest in a legal entity, or the names of all members of an LLC. This reporting requirement runs from August 28, 2016 through February 23, 2017.
FinCEN Expands Reach of Real Estate “Geographic Targeting Orders” Beyond Manhattan and Miami
U.S. Title Insurers Required to Identify High-End Cash Buyers in Six Major Metropolitan Areas