Hello Anthony, hello Claudine. Today, we're here to talk about some real estate issues we had discussed back in April. FinCEN, the Financial Crimes Enforcement Network, recently issued a press release addressing real estate secrecy in Manhattan and Miami. They introduced Geographic Targeting Orders (GTOs) that require identification for high-end cash buyers. Originally effective from March 1, 2016, the orders were set to expire on August 27th. However, I reminded myself to do a search on that day, and to my surprise, there was a new press release stating the expansion of the target areas. The initial target areas were Manhattan and Miami-Dade County in Florida. The GTOs temporarily mandated certain US title insurance companies to identify individuals with at least 25 percent ownership in companies used for all-cash purchases of high-end residential real estate. This information was then reported to FinCEN and made accessible to law enforcement investigators through their database. The objective was to catch criminals who launder money through cash transactions. One significant aspect of the program is that it supports government employment. The target seems to be Russian mobsters who bring their money to the US for real estate investments while avoiding taxes. Although there are unethical individuals worldwide, we still accept their money because it contributes to taxation. It is a peculiar situation as the entire purpose of this program can be bypassed simply by not getting title insurance. Title insurance companies charge a premium on the title with a major portion going to the attorney. As someone who used to sell title insurance, I found it fascinating to enlighten people about this aspect. However, now as a buyer, I must pay for title insurance, and it can be quite costly. Thus, I no longer handle real estate closings.
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Fincen gto 8300 Form: What You Should Know
The transaction must involve any of the following: Title insurance (Title 1) or Property/Business/Liability Insurance (Title 2, for certain business entities) or Business/Liability insurance issued by WIG (W IG) In addition the covered transactions must involve property owned, leased, or occupied by WIG or related entities; and A Covered Transaction does not include: A. Receipts to the same entity (e.g., WIG or its related or affiliated companies) for the same goods, services, or property provided under the Agreement; B. Contracts entered into with the same entity (e.g., real estate purchases by WIG or its related or affiliated companies) under separate written contracts; C. Payments of the purchase price in cash; or D. Payments of commission for working with WIG business. On August 27, 2016, a Form 8300 was issued by Fin CEN for WIG National Title Insurance, Inc. (WIGNER) to comply with Fin CEN's WIG GTO. This document includes information regarding WIGNER's insurance business and WIGNER's policy and contract language for title insurance and/or property/business/liability insurance (including, in this Form 8300, the coverage limits of WIGNER's policies and contracts; the types of assets and liabilities covered; the terms of the respective policies and contracts; and the policy and contract language for the receipt of payments in cash). On May 26, 2017, a Form 8300 was issued for WIGNER by Fin CEN (“Fin” for short) for compliance with Fin's Form 8300 for WIGNER, which Fin issued on June 6, 2016. On May 6, 2016, Fin CEN issued a Final Rule on Fin's Final Decision regarding WIGNER which was based on the evidence submitted by Fin in the application. The Final Decision required WIGNER to comply with Fin CEN's Order regarding the filing of required reports to Fin CEN. Under the Final Decision, Fin CEN determined that Fin CEN Order issued and all related amendments were valid and enforceable and applied to WIGNER. The Final Decision provides that WIGNER could have been required to file reports to Fin CEN as of March 1, 2007, in its original and amended Form 8300 for WIGNER.
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