The Financial Crimes Enforcement Network (FinCEN) on July 27 announced new Geographic Targeting Orders temporarily requiring all U.S. title insurance companies to identify the individuals behind companies used to conduct high-end, all-cash real estate transactions in six major jurisdictions. The GTOs are effective for 180 days beginning on Aug. 28 and apply to underwriters’ subsidiaries and agents. Click here for more on the order.
ALTA has created several documents to help title professionals comply with FinCEN’s order.
- ALTA FAQ for August 2016 Geographic Targeting Orders: This document highlights the basics of the GTO, covered jurisdictions, what information must be collected and criminal penalties for not complying
- Covered Transaction Determination Form: This form will help determine if a transaction is a “Covered Transaction” under the GTO.
- Information Collection Form: This document will aid in the collection of information for “Covered Transactions.”
In addition, ALTA has created a handout that title professionals can provide to real estate professionals to explain the GTO: