Here’s What’s Changing in the FinCEN Geographical Targeting Order

The Director of the Financial Crimes Enforcement Network (FinCEN) announced yesterday, (July 27, 2016) that they are EXTENDING the reporting requirements that are contained in the Geographical Targeting Order (GTO) that was put into effect on March 1. The original GTO was set to expire on August 27, 2016. It is now extended until February 23, 2017.

Local Expansion

They will also be EXPANDING the transactions that will have to be reported under the GTO. Transactions on properties in Kings (Brooklyn), Queens, Bronx and Richmond (Staten Island) Counties will now be included in the reporting criterion, along with New York County (Manhattan) which was already in effect.

Qualified Transactions

The local (NYC) transactions that are covered are those that are:

1 – Residential in nature

2 – Purchased by a “legal entity” as opposed to a natural person

3 – Purchased without “bank financing”

4 – Where the purchase price is in excess of $3,000,000 in New York County and $1,500,000 in the remaining counties

For transactions that qualify under these guidelines, Title Insurance Companies and their Agents will be required to submit a report to FinCEN providing the IDENTITIES of the beneficial owners and primary representatives of the legal entity that is purchasing the property together with other relevant information regarding the transaction (for a more detailed explanation of reporting requirements you can read our original article here: http://macgregorabstract.com/?q=ny-real-estate-and-swiss-bank-accounts )

National Scope

The original GTO also included Miami Dade County in Florida, and the scope of the new GTO extends its coverage to affect similar transactions in two additional Florida counties immediately north of Miami Dade: Broward and Palm Beach. It also now covers transactions in California: Los Angeles County, three counties in the San Francisco area and San Diego County. Transactions in Bexar County, Texas (San Antonio area) are now also included.

Additional Information

A copy of the order can be viewed at https://www.fincen.gov/news_room/nr/pdf/20160727.pdf

The home page for the FinCEN can be viewed at https://www.fincen.gov/

FinCEN’s news release can be viewed at https://www.fincen.gov/news_room/nr/html/20160727.html

For more information regarding the original GTO, read our previous article here: http://macgregorabstract.com/?q=ny-real-estate-and-swiss-bank-accounts

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