ALTA Survey, Gov't Shutdown & Expanded FinCEN GTO
Hello Fund Members!
I just got back from the Florida Land Title Association Convention and listened to several very good presentations on different aspects of our industry. The one that made the biggest impression on me was, of course, about the ever-evolving face of cyber fraud presented by Tom Cronkright of CertifID. The fraudsters are definitely leveraging technology to find new ways to fool you (and others). Help the industry out by completing the ALTA cyber crime survey. You do not need to be a member of ALTA to complete the survey and your experiences will help ALTA present a comprehensive picture of what is going on from our perspective. Here is a link to the study. Complete the study today
Government Shutdown? Once again, a potential government shut down is looming on November 17, 2023. How will a shut down affect your ability to get closings done? Some quick research by Jay St. Lawrence, Fund Regulatory Compliance Counsel, tells us this:
- The IRS will not respond to lien payoff requests (based on a Member’s experience related to me)
- FHA single family loans can be processed, but Reverse (HECM) and Title I (renovation) loans cannot
- VA loans should continue to be processed
- HUD loans should not stop processing single-family loans, but may move slowly
- HUD will be unable to approve loans for multifamily projects
- The USDA will stop processing new loans and loan guarantees
- SBA will not process new loans or loan modifications
- The National Flood Insurance Program insurance will not issue new policies
You might want to start reviewing your open/pending files to see if any of the above will have an impact. We might discover other challenges and if we do, we will share them with you. And please share any experiences you have with us! Better yet, let's hope Congress works it out.
FinCEN's Geographic Targeting Order has been expanded to cover 8 more counties in Florida. Transactions that meet the requirements/parameters of the GTO in Miami-Dade, Palm Beach, Broward, Hillsborough, Pasco, Pinellas, Manatee, Sarasota, Charlotte, Lee and Collier are subject to the reporting requirements of the GTO. For those of you who need to learn about the requirements (or need a refresher course), tune into the Title Now Popup Webinar on GTOs on November 15 at Noon. 30 minutes. The Fund's Regulatory Compliance Counsel, Jay St. Lawrence, will join me in a discussion about these requirements. And it's FREE! Register here https://register.gotowebinar.com/register/8641532908600987232
That's all for this week. Let me know how we can help you.
Melissa Jay Murphy
Executive Vice President, Chief Legal Officer,
and General Counsel
11/09/2023