UPDATE! FinCEN GTO has changed!
Juliana Tu
Certified Senior Escrow Officer of Viva Escrow! Inc. and 2019 President of the California Escrow Association
URGENT ! FinCEN GTO is updated! Our website has an article of the FinCEN Geographical Targeting Order that was issued for past year(s). As of today, May 21, 2018, the GTO has changed. Changed paramaters are unknown as there is a "Confidential Agreement" signed between FinCEN and American Land Title Association (ALTA) - the organization representing the underwritten Title Insurance Companies. Disclosure of any part of this Confidential Agreement by members of ALTA will carry steep criminal and other penalties apparently.
Because of this incredible challenge that they are not able elaborate or disclose, many of the Title Companies are going to require their ALTA Information Collection Form be completed by the Buyer, irrespective of sale price, type of Buyer entity or any other previously known markers. They have advised us that they WILL NOT allow a transaction to close and issue a Policy of Title Insurance if this form is not completed if requested in that particular file.
Escrow Professionals and concerned real estate agents - Be advised and contact your Title Officer. This Information Collection Form has changed also.