Really Important Info on Sanctions, Data Call, RON Obligation and DoubleTime

Dear Members,

OMG. There is a lot going on…. so this blog is overflowing with information for you. I hope you find it helpful. (Personal note: I hate Daylight Savings Time. But I love MARCH MADNESS!!! It starts this week and it is one of my favorite times of the year. So if I am slow in responding to an email…………)

ALERT - CLOSINGS INVOLVING SANCTIONED RUSSIAN ENTITIES/INDIVIDUALS.  Closings and transfers of money involving persons (including entities) on the OFAC Sanctions List are prohibited.  The Office of Foreign Assets Control (OFAC) has updated its Sanctions List pursuant to an Executive Order issued by President Biden related to the situation in Ukraine.  YOU ARE RESPONSIBLE FOR SEARCHING THE LIST FOR LENDERS AND BUYERS INVOLVED IN YOUR TRANSACTION.  THIS INCLUDES BOTH LENDERS LOANING NEW MONEY AND LENDERS RECEIVING A PAYOFF OF AN EXISTING LOAN.  If we are providing you with a branch product/commitment, we will search ONLY the names of the sellers and borrowers.  This is not new but the whole point of this alert is that the list of suspect entities/persons HAS BEEN SIGNIFICANTLY EXPANDED and may affect more transactions than before. Here is a link to search the OFAC Sanctions List.  Here is a link to our Alert that went out to all Members.  You cannot close on a transaction involving persons/entities on the list!  Please reach out to me or underwriting if you have any questions. 

TITLE AGENCIES - DATA CALL REMINDER.  Don't forget about your annual obligation to complete and file the Data Call required by OIR.  Your deadline this year is Sunday May 31, 2022.  There are no exceptions……even if you closed your agency in 2021, you are obligated to file.  Not sure what the penalties are but I guess they might flag your individual license if you fail to file????  Avoid any problems and file. Your data is very important to the industry. 

Here is a link to information on the DFS website:

NEW OBLIGATION FOR ONLINE NOTARIES (RON).  Currently registered Florida online notaries public (RONs) are now required to provide the Department of State with the name(s) of their RON service provider(s) and, if applicable, the name(s) of any secured depositories to whome they have delegated duties pursuant to Sec. 117.245(4), F.S.   Rule 1N-7.005, F.A.C., effective Feb. 22, 2022, allows current RONs 30 days from the effective date (March 24) to comply while new registrants will submit the information with their initial application.  The report shall be made using Form DS-DOC-50 which may be completed online or submitted by email.  Any future changes occurring to the information provided (updates, additions, or removals) require the submission of a new form within 30 days of the changes.  Information about submitting the report can be found at the bottom of the form.

NEW DOUBLETIME UPDATE - INSTALL ASAP.  The IRS has changed the data file format sent into their FIRE (filing information returns electronically) system.  To ensure the IRS receives the 1099-S file in the correct format, a mandatory update to DoubleTime 9.1 is required.  Here is a link to the information you need to get this update done.

I think that's enough for this week!

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