Gators & More: Bills, DoubleTime & BOI Reporting

Hello Members!

Whew! Can you believe it???? Gators made it into the Final Four! Whoo hoo. Stressful games for Gator fans but exciting nonetheless. Duke made a definite statement against Alabama (much to my nephew’s dismay). Auburn is our next challenge. Go Gators!

I found a few interesting bills to talk about that have zero to do with real estate, but that's the privilege of being the editor of these blogs: I get to pick! There's other stuff, too, that I think you will find of interest.

School Hours and License Tags.  I found these bills interesting but not particularly applicable to your real estate practice.

• HB 261 is working its way through the committees. This bill would reverse the decision from a few years ago that would have required middle and high schools to start later in the day, effective in 2026. After a year of urgent pleas from some school districts about the challenges of complying with this change, lawmakers are backing off of the mandate BUT still pushing those school districts that can manage a later start date to continue with that change. Other school districts just have to submit a report that documents how they tried to move to later start times and what impacts (financial and other) they encountered that would keep them from supporting this move. So if you care about this and didn't like the change, it looks like you get a break. If you liked the change made by your district, they can keep the change.
• SB 92 is an effort to help law enforcement to make arrests in hit-and-run car crash cases. The bill would require FRONT and rear license plates on Florida-registered cars. This would help with witnesses and surveillance cameras. Also, auto repair shops are required to report certain types of high-value repair requests to law enforcement (in excess of $2500). It is not clear how requiring a second license plate would affect registration fees (double?), but we will see whether this bill will make it through the rest of its committee stops.

DoubleTime Retirement Delayed but Still Happening/Fund Assembly. This may violate the "one topic per paragraph" rule of a blog, but it's important. We received a lot of feedback from many Members, primarily those using DoubleTime, that more time to find new closing software would be very beneficial. The Fund's Executive Management Team heard you and decided that an extension of the retirement date for DoubleTime was the right thing to do. We recognized that because ClosingVue is no longer a long-term solution, Members are back to square one of evaluating closing software products.

So DoubleTime's retirement has been extended to June 30, 2026. We hope this information will indicate that we are not ignoring the challenges the recent changes present, but we also want to be very clear that the decision to ultimately retire DoubleTime is not under discussion. June 30, 2026 is a definite deadline. We are sharing this information with all Members through many different channels because of our commitment to communicating transparently and broadly, even though some of you are not DoubleTime users.

One more thing. We continue to get feedback that some Members believe there is a push or even a requirement that you use Qualia. We want to emphasize again that there is no such requirement. So in order to support you as best we can, we are working every day with other software vendors to expand the products with which we have the necessary integrations to make your workflow as efficient as possible. We will continue to keep you updated on those software options.

Sorry. One more thing. Fund Assembly is a great opportunity for you to learn more. All of the vendors with whom we have integrations or are working on integrations will be there! You will be able to interact one-on-one with those companies, see demos and start on evaluating which one might be best for you. Please join us in Orlando! Here is a link to register: https://www.thefund.com/assembly

BOI Reporting Requirements Under the Corporate Transparency Act. Not a week goes by without yet another update on whether the BOI reporting requirements under the CTA are still in effect, have been delayed, or even eliminated. The newest information we have is that FinCEN has issued an interim final rule that removes the requirement for reporting BOI information on U.S. companies. In the final rule, the definition of a "reporting company" was revised to mean only those entities formed under the law of a foreign country. Additionally, these foreign entities will not be required to report any U.S. persons who are beneficial owners. For more details, read this ALTA posting.  FinCEN Eliminates BOI Reporting Requirements for U.S. Companies. Lastly, there is some "hope" that this will affect the implementation of the Anti-Money Laundering Rule set to go into effect December 1, 2025. There is no such information now, but this could actually work against the delay of this rule because the data provided by closing agents is more valuable. (Sigh). I will keep you posted on this as best I can.

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