An Important Reminder about the Latest FinCEN Government Targeting Order

Included in this email: FinCEN GTO Reminder, and Wire Fraud Information Now Available in an Audio Version! 

Dear Members,

Happy Birthday, USA! I hope you found time to celebrate this great holiday and spend some quality time with your families. I am headed to Georgia for a family reunion of one branch of the family and I am looking forward to catching up with all of them.

FinCEN Government Targeting Order Reminder

Please, please familiarize yourself with the terms and conditions of the current FinCEN GTO. We sent the new GTO out to all Fund Members in early May but have recently gotten some indications that many of you are not aware of it. Click here for a copy of the GTO and additional information about how to advise your client. You will need your Member login information.

Wire fraud Information

Over 100 of you responded to the two-question survey about possible resources to help protect you against wire fraud. The responses were mostly "yes" you are interested in finding out more. There is generally a willingness to pay but there was quite a range in what you felt was a reasonable charge. We have talked to a few vendors and it is interesting to see the very different ways they approach a solution. One vendor uses technology to determine whether an email sent to the closing agent is coming from a device (laptop, cell phone, etc.) that appears legitimate.

For example, if an email is being sent from a computer whose ISP address shows it being located in the Ukraine, the vendor will alert you and say "hey - wait a minute. Is your seller in the Ukraine?" This vendor can also determine if the device has been compromised by malware. Another vendor takes a different approach and has created a separate, secure line of communication that you can use when you communicate with the buyer or seller regarding wire instructions. These communications go outside your normal email system (e.g., Outlook) and are secure. All very interesting and we are continuing to evaluate these options in order to better advise you on things you can do to prevent wire fraud.

Let me know how we can help you.


Melissa Jay Murphy
Executive Vice President, Chief Legal Officer,
General Counsel and Secretary