On 11/4/2020, FinCEN Director Kenneth Blanco issued a renewal of a Geographic Targeting Order that requires title insurance companies to collect and report information about the persons involved in certain residential real estate transactions. This order covers certain transactions in which residential real property is purchased by a legal entity in the amount of $300,000 or more without the use of a loan in the following areas:
The Texas counties of Bexar, Tarrant, or Dallas;
The Florida counties of Miami-Dade, Broward, or Palm Beach;
The Boroughs of Brooklyn, Queens, Bronx, Staten Island, or Manhattan in New York City, New York;
The California counties of San Diego, Los Angeles, San Francisco, San Mateo, or Santa Clara;
The City and County of Honolulu in Hawaii;
The Nevada county of Clark;
The Washington county of King;
The Massachusetts counties of Suffolk, or Middlesex; or
The Illinois county of Cook;
In conjunction with the geographic targeting orders, FinCEn has also released a set of FAQs to help clarify the requirements.
The full Geographic Targeting Order can be found here.
The FinCEN FAQs can be found here.