GTO Targeting Order Regarding FinCen Reporting Requirements

Buyers that are purchasing a property through a corporation, limited liability company (LLC), partnership, and other similar legal entity should be aware of the federal government reporting rules.

Current Geographic Targeting Order (GTO) issued by the Financial Crimes Enforcement Network of the U.S. Department of Treasury (FinCEN) requires that a Buyer or a closing agent on behalf of the Buyer provide a specific reporting to FINCEN.   The following is the reporting criteria:

• Purchase of residential Property;
• In Miami-Dade, Broward, or Palm Beach County;
• For $300,000 or more;
• By a corporation, limited liability company (LLC), partnership, or other similar legal entity, except U.S. publicly traded companies or their subsidiaries;
• Without a bank loan or other similar foam of institutional financing.  

This means that if a Buyer is purchasing a residential property for or over $300,000 with either cash or private loan and wants the deed to state the name of the company or a corporation, that Buyer falls under the GTO FinCen reporting requirement.