FinCEN Geographic Targeting Order Renewal and Changes

By Rosemary Liuzzo Mohamed

The FinCEN Geographic Targeting Order has been extended once again, now until May 15, 2019. With the extension came some new changes to the Order.

New counties have been added to the Order. The list now includes residential real property located in Tarrant and Dallas Counties, State of Texas; Cook County, State of Illinois; Clark County, State of Nevada; Suffolk and Middlesex Counties, State of Massachusetts; and King County, State of Washington. The following, which were all listed on the previous Orders, still remain: New York, Kings, Bronx, Queens & Richmond Counties, State of New York; Bexar County, State of Texas; Honolulu County, State of Hawaii; San Diego, Los Angeles, San Francisco, San Mateo and Santa Clara, Sate of California; and Miami-Dade, Broward and Palm Beach Counties, State of Florida.

Other changes include the removal of purchases through a Trust and the removal of certain confidentiality provisions.

Now, a covered transaction will include any purchase of residential real property by a legal entity (excluding trusts), in the above mentioned locations, with a purchase price over $300,000.00, without institutional financial lending. If the transaction is covered under the Order, the title company will be required to report identity information of the parties of the legal entity to FinCEN.