Sunday, November 18, 2018

FinCEN: The Original Detroit GTO Model Of Corporate Shape Shifting Races For LLC Property Titles

I bet the Corporate Shape Shifters over there at Title Source/Amrock/Quicken Loans/Bedrock/Jack Entertainment whatever the TITLE INSURANCE COMPANY flavor of the week it is for Dan Gilbert is most certainly glad that Detroit was not identified in these new Geographic Targeting Orders (GTO), but, then again, Detroit was the original model.


Title Source Has Been Anointed As A $706 Million Corporate Shape Shifter


GEOGRAPHIC TARGETING ORDER The Director of the Financial Crimes Enforcement Network (“FinCEN”) hereby issues a Geographic Targeting Order (“Order”) requiring TITLE INSURANCE COMPANY to collect and report information about the persons involved in certain residential real estate transactions, as further described in this Order.

Now, this is how you target populations.

Karma.
Purchase Threshold Lowered to $300,000 and Virtual Currencies Included

WASHINGTON—The Financial Crimes Enforcement Network (FinCEN) today announced the issuance of revised Geographic Targeting Orders (GTOs) that require U.S. title insurance companies to identify the natural persons behind shell companies used in all-cash purchases of residential real estate. The purchase amount threshold, which previously varied by city, is now set at $300,000 for each covered metropolitan area. FinCEN is also requiring that covered purchases using virtual currencies be reported.


Previous GTOs provided valuable data on the purchase of residential real estate by persons implicated, or allegedly involved, in various illicit enterprises including foreign corruption, organized crime, fraud, narcotics trafficking, and other violations. Reissuing the GTOs will further assist in tracking illicit funds and other criminal or illicit activity, as well as inform FinCEN’s future regulatory efforts in this sector.

Today’s GTOs cover certain counties within the following major U.S. metropolitan areas: Boston; Chicago; Dallas-Fort Worth; Honolulu; Las Vegas; Los Angeles; Miami; New York City; San Antonio; San Diego; San Francisco; and Seattle.

FinCEN appreciates the continued assistance and cooperation of the title insurance companies and the American Land Title Association in protecting the real estate markets from abuse by illicit actors.
Any questions about the Orders should be directed to the FinCEN Resource Center at FRC@FinCEN.gov 

Frequently asked questions regarding these GTOs are available here.
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