If you were hoping for a reprieve from having to identify all-cash buyers above a certain price point in certain counties to the Financial Crimes Enforcement Network (FinCEN) — sorry.

  • Title professionals must continue to identify all-cash buyers who purchase properties above different price thresholds in several counties or metropolitan statistical areas in California, Florida, Texas and New York.

If title professionals were hoping for a reprieve from having to identify all-cash buyers above a certain price point in certain counties to the Financial Crimes Enforcement Network (FinCEN) — sorry.

Today, the network announced that it was renewing its current geographic targeting order (GTO) through August 22, 2017.

The current locations affected by the order include:

  • All boroughs of New York City
  • Miami-Dade, Broward and Palm Beach counties in Florida
  • Los Angeles County
  • San Diego County
  • Three counties comprising the San Francisco Bay Area
  • The county including San Antonio, Texas

“These GTOs are producing valuable data that is assisting law enforcement and is serving to inform our future efforts to address money laundering in the real estate sector,” said FinCEN Acting Director Jamal El-Hindi in a statement. “The subject of money laundering and illicit financial flows involving the real estate sector is something that we have been taking on in steps to ensure that we continue to build an efficient and effective regulatory approach.”

“Our members have collected this information for more than a year and the good news is those efforts appear to be beneficial to the government’s work identifying money laundering schemes and the illegal purchase of real estate,” said Michelle Korsmo, the American Land Title Association’s chief executive officer, in a statement. “We continue to work closely with our members and FinCEN to collect the needed information as efficiently as possible.”

Each market has a different threshold for scrutiny. In California counties surveyed, the cutoff will be at homes selling for $2 million or higher.

This means that buyers paying cash and using an LLC to purchase property that’s priced at $2 million or above in California will be subject to the rule.

In San Antonio, however, the cutoff is $500,000. See the full list of values below.

FinCEN also provided a sample GTO and an example of form 8300, which title companies must file for all “covered transactions” within 30 days of closing.



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