On October 19, 2023, the Financial Crimes Enforcement Network (FinCEN) has once again issued a Geographic Targeting Order (“GTO”). The most recent GTO received by First National Title Insurance is attached hereto. Please refer to prior bulletins and to the actual GTO for the full reporting details.
GTO PERIOD:
FOR COUNTIES AND BOROUGHS PREVIOUSLY INCLUDED IN THE GTO, THE GTO HAS BEEN EXTENDED EFFECTIVE OCTOBER 22, 2023, AND CONTINUING THROUGH APRIL 18, 2024.
FOR THE NEWLY ADDED TEXAS COUNTY OF TRAVIS, AND THE NEWLY ADDED FLORIDA COUNTIES OF HILLSBOROUGH, PASCO, PINELLAS, MANATEE, SARASOTA, CHARLOTTE, LEE AND COLLIER; AND THE NEWLY ADDED MASSACHUSETTS COUNTIES OF BRISTOL, ESSEX, NORFOLK, AND PLYMOUTH, THE GTO IS EFFECTIVE NOVEMBER 21, 2023, AND CONTINUES THROUGH APRIL 18, 2024.
If you are closing transactions in any one of the “Newly Added” counties or boroughs, and you have not previously closed transactions in counties or boroughs subject to the GTO, please be sure you read the GTO and become very familiar with the reporting requirements.
COVERED COUNTIES:
For the cash purchase of residential real property by a “Legal Entity” (as this term is defined in Section III. A. of the GTO) where the purchase price of the property is in the amount of $300,000.00 or more, the following counties are affected by the GTO:
Texas Counties of Bexar, Tarrant, Dallas, Harris, Montgomery, Webb and Travis
Florida Counties of Miami-Dade, Broward, Palm Beach, Hillsborough, Pasco, Pinellas, Manatee, Sarasota, Charlotte, Lee and Collier
The Boroughs of Brooklyn, Queens, Bronx, Staten Island, and Manhattan in New York City, NY
California Counties of San Diego, Los Angeles, San Francisco, San Mateo, and Santa Clara
Hawaii Counties of Hawaii, Maui, Kauai, Honolulu and the City of Honolulu
Nevada County of Clark
Washington County of King
Massachusetts Counties of Suffolk, Middlesex, Bristol, Essex, Norfolk and Plymouth
Illinois County of Cook
Maryland Counties of Montgomery, Anne Arundel, Prince George’s, and Howard
Virginia Counties of Arlington and Fairfax, and the Cities of Alexandria, Falls Church, and Fairfax
Connecticut Counties of Fairfield and Litchfield
Colorado Counties of Adams, Arapahoe, Clear Creek, Denver, Douglas, Eagle, Elbert, El Paso, Fremont, Jefferson, Mesa, Pitkin, Pueblo, and Summit
The District of Columbia
Additionally, purchases of residential real property by a “Legal Entity” (as this term is defined Section III. A. of the GTO) in the amount of $50,000.00 or more in the City or County of Baltimore, Maryland is subject to the GTO.
Purchases by individuals, purchases using a bank or mortgage company loan, or purchases made by entities that are publicly traded in the US are not required to be reported.
Helpful Links:
Forms and additional information can be obtained through the FinCEN Resource Center at [email protected].
The FinCEN Resource Center may be contacted by phone at 800-767-2825, Monday through Friday, 8am to 6pm ET.
As always, your FNTI team is available to help with questions and guidance.
Previously issued Bulletins on the FinCEN GTO can be located on the FNTI website at
https://fnti.com/agents/bulletins/agency-bulletins/:
Agency Bulletin AGTX/FL-2016-005 dated 8/18/2016
Agency Bulletin AGTX/FL-2017-002 dated 2/22/2017
Agency Bulletin AGTX/FL-2017-005 dated 8/24/2017
Agency Bulletin AGTX/FL-2018-001 dated 3/27/2018
Agency Bulletin AGTX/FL-2018-005 dated 11/26/2018
Underwriting Bulletin UNTX.FL-2019-001 dated 5/22/2019
Agency Bulletin AGTX/FL-2019-008 dated 11/11/2019
Agency Bulletin AGTX/FL/NV-2020-004 dated 5/13/2020
Agency Bulletin AGTX/FL/NV-2020-007 dated 11/6/2020
Agency Bulletin AGTX/FL/NV-2021-001 dated 4/30/2021
Agency Bulletin AGTX/FL/NV-2021-006 dated 10/29/2021
Agency Bulletin AGNAT-2022-009 dated 5/2/2022
Agency Bulletin AGNAT-2022-015 dated 10/28/2022
Agency Bulletin AGNAT-2023-002 dated 5/12/2023
| File | Action |
|---|---|
| 1698175029wpdm_AGNAT-2023-006.pdf | Download |
