Reader – please take note – there is a change in the Financial Crimes Enforcement Network’s (FinCen) Geographical Targeting Order (GTO).
Now that I have your attention, I am sorry to say that I will now disappoint you with the limited scope of information that I am at liberty to convey. The terms of the GTO are confidential. That’s right, CONFIDENTIAL. That means that I (and every other Title Insurance professional) am prohibited from telling you anything about the terms. The only thing that we are allowed to say is that there is a confidential order that must be complied with.
You will immediately begin to see a new exception in your title reports to address this issue. You may, from transaction to transaction, be asked for certain information without any detailed explanation as to why we are asking for it, or what has triggered the request. The only thing we will be able to say is that there is a confidential order that must be complied with. Please understand that without compliance to these demands, we will not be able to issue a title insurance policy to facilitate your closing.
My opinion – this sounds unreasonable.
My decision – we will comply.
Please accept my apologies in advance for any difficulties, frustrations, or delays that this may cause. This new course of action was not devised by the Title Insurance companies or their agents, but we will do our best to help you through this process if and when it impacts the transactions that you are attempting to insure.