Summary of Key Points

This Geographic Targeting Order (GTO) issued by the Financial Crimes Enforcement Network (FinCEN) requires Title Insurance Company to report cash payments over $3 million in real estate transactions.

Coverage

The GTO applies to all real estate transactions involving cash payments in excess of $3 million.
The Covered Transaction must be reported on Form 8300 within 15 calendar days after the date of the transaction.

Part II: Report of Cash Payment Over $3 Million

Field 25.z: Total purchase price of the Covered Transaction and method of payment.
Fields 25 a – i: Leave blank.

Part III: Property Address and Purchase Price

Fields 33-37: Address of real property involved in the Covered Transaction.
Field 41: Total purchase price of the real property listed in Fields 33-37. (If multiple properties are purchased in the same transaction, report total purchase price in Part II, Field 25.z, and price per property in Field 41 for each property.)

Part IV: Covered Business Information

The Covered Business must ensure that the term “REGTO0521” remains in Field 45.

General Provisions

Definitions

Beneficial Owner: An individual who owns 25% or more of the equity interests of a Legal Entity.
Legal Entity: A corporation, limited liability company, partnership, or similar business entity.

Order Period

The GTO is effective from May 5, 2021, to October 31, 2021 (unless otherwise provided in Section III.C).

Retention of Records

Covered Businesses must retain records for five years and make them available upon request by FinCEN or other law enforcement agencies.

Confidentiality

The GTO is not confidential.

Compliance

Covered Businesses are responsible for supervising compliance by their officers, directors, employees, and agents.

Penalties for Noncompliance

Covered Businesses and their officers, directors, employees, and agents may be liable for civil or criminal penalties.