FinCEN Reporting to Now Include Wire Transfers!

FinCEN is expected to issue NEW GTOs effective September 22, 2017.

Dear Members,

There’s never a dull moment in the FinCEN world. If you handle residential transactions in Dade, Broward or Palm Beach counties, hear this!

• The current Geographic Tracking Orders (“GTOs”) expire on August 22, 2017.
• FinCEN is expected to issue NEW GTOs effective September 22, 2017. The new GTOs will include the same terms as the current GTOs with the following additions:
  1. Wire transfer will join currency, cashier’s check, certified check, traveler’s check, personal check and money order as a form of payment creating a covered transaction. THIS IS THE SIGNIFICANT CHANGE.
  2. The city and county of Honolulu will be added to the geographic areas subject to the current GTOs. (This obviously does not affect your day to day practice here in Florida but I thought you might like to know.)
• Transactions closing between August 23, 2017 and September 21, 2017 do not have to be reported to FinCEN. There will be no requirement to obtain information about the identity of Beneficial Owners of the purchasing business entities for transactions closing during that period.

Reminder: FinCEN’s Geographic Tracking Orders require all title insurers and title insurance agents to report certain information about Covered Transactions. To qualify as a Covered Transaction the purchaser must be a business entity such as a corporation, LLC or partnership and acquire residential property with a purchase price of $1,000,000 or more without obtaining an institutional mortgage. GTOs on Florida are limited to Dade, Broward and Palm Beach counties.

When the new GTOs are issued, we will make them available to you. You will receive more detailed information from us as we get a bit closer to the September 22, 2017 effective date.

Revised Board Certification Credit for Fund Assembly 2017

We are pleased to let you know that The Florida Bar has revised the accreditation to include additional certification credits as follows:

• General Session now includes 2.0 hours Board Certification in Condominium and Planned Land Development Law (Course reference 1701043N)
• Commercial Track now includes 3.0 hours Board Certification in Condominium and Planned Land Development Law (Course reference 1701126N)

Speakers for Fund Assembly 2018

While we are on the topic of Fund Assembly, are you interested in being a speaker at either the General Session or one of the Break-out sessions? Do you have a topic that you think would be of significant interest to Fund Members? If so, we are soliciting speaker applications from Fund Members for the Fund Assembly in 2018. The specific dates are May 10, 11 and 12, 2018.

Deadlines for getting your presentation summary, biographical sketch and head shots will be mid-January, 2018 and the delivery deadline for your full materials is March 16, 2018. Take these dates into account before you decide to submit a topic because these deadlines are very important to us. Here is a link to the online form.  

Let me know how we can help you.

Best Regards,
Melissa Jay Murphy
Senior Vice President and General Counsel