Dear Agents:
The Financial Crimes Enforcement Network (FinCEN), as it has done for the past several years, once again has issued a Geographic Targeting Order (GTO) on April 29, 2022, to extend the expiration date thru October 26, 2022, unless otherwise extended further. The most recent GTO received by First National Title Insurance is attached hereto.
As a reminder, the GTO requires reporting of purchases of any residential real property located in various states and counties by a legal entity (which is defined in the GTO.) There are significant changes from the most recent GTO from prior orders adding several states to the requirement for reporting residential real property purchases of $300,000 but most notably is that the dollar amount threshold for the City or County of Baltimore in Maryland is $50,000.
For the following states and counties in an amount of $300,000 or more by any legal entity without a bank loan or other similar form of external financing, reporting is required:
Texas: Counties of Bexar, Tarrant, or Dallas;
Florida: Counties of Miami-Dade, Broward, or Palm Beach;
Hawaii: Counties of Hawaii, Maui, Kauai, or Honolulu, or the City of Honolulu
Nevada: Clark County
Washington, King County
Massachusetts: Counties of Suffolk or Middlesex
Illinois: Cook County
* Maryland: Counties of Montgomery, Anne Arundel, Prince George’s, or Howard
Virginia: Counties of Arlington or Fairfax, or the Cities of Alexandria, Falls Church, or Fairfax
Connecticut: Fairfield County
District of Columbia
* Maryland: City of County of Baltimore – sale price of $50,000 or more requires reporting
Purchases by individuals are not required to be reported nor does the GTO require reporting for purchases made by legal entities that are United States publicly-traded companies.
FNTI continues to monitor all communications from FinCEN, the American Land Title Association, and the Texas Land Title Association regarding the GTO and may amend the above information should we become aware of necessary and/or needed changes. Not only are we at FNTI available for questions, the FinCEN Resource Center may be contacted at 800-767-2825, (Monday thru Friday from 8 a.m. to 6 p.m. Eastern time).
(Previously issued Bulletins (may be renumbered and differ from last bulletin issued) are locatable on FNTI’s website, https://fnti.com/agents/bulletins/agency-bulletins/:
Agency Bulletin AGTX/FL-2016-005 dated 08/18/2016
Agency Bulletin AGTX/FL-2017-002 dated 02/22/2017
Agency Bulletin AGTX/FL-2017-005 dated 08/24/2017
Agency Bulletin AGTX/FL-2018-001 dated 03/27/2018
Agency Bulletin AGTX/FL-2018-005 dated 11/26/2018
Underwriting Bulletin UNTX.FL-2019-001 dated 05/22/2019
Agency Bulletin AGTX/FL-2019-008 dated 11/11/2019
Agency Bulletin AGTX/FL/NV 2020-004 dated 05/13/2020
Agency Bulletin AGTX/FL/NV-2020-007 dated 11/6/2020
Agency Bulletin AGTX/FL/NV-2021-001 dated 04/30/2021)
Agency Bulletin AGTX/FL/NV-2021-006 dated 10/29/2021
Thank you for being part of the FNTI Agency family.
| File | Action |
|---|---|
| 1651500149wpdm_AGNAT-2022-009.pdf | Download |
