Bulletin: NY000580

Date:
February 25, 2016
To:
All New York State Agents
RE:
US Department of Treasury: Financial Crimes Enforcement Network (FinCEN) Geographic Targeting Order, New York County, NY

This bulletin is further guidance on the January 13, 2016 FinCEN Geographic Targeting Orders (GTO).  As suggested in Bulletin NY000578, Stewart advised you to begin to alert your customers and proposed insured of the GTO reporting requirement commencing on 3/1/2016.  Attached to this bulletin is Stewarts suggested requirement language to be included in your title report/title commitments.  Also as a reminder:

Stewart will require all offices and agents to file the form 8300 within thirty (30) days on all covered transactions for as long as the order is in place directly with FinCEN.  All agents and offices should report evidence of the filing to Stewart via the over limits/high liability system.  A copy of the form 8300 completed and signed together with the required beneficial owner identification and copies of the proofs taken should be attached to an over limits form and submitted to:  HighLiPolicy@stewart.com.  You will not receive an approval of the submission.  This submission is for record keeping purposes. 

Please note the instruction of form 8300 require the form to be signed by an individual who has been authorized to do so for the party that received the proceeds of sale.

Attachments: IRS/FinCEN 8300FinCEN Exceptions; Frequently asked Questions; ALTA Fact Sheet; First Calls Schedule

In the event you have any questions, please the Stewart Title Insurance Company- New York Legal Department at (212) 922-0050.

THIS BULLETIN IS FURNISHED TO INFORM YOU OF CURRENT DEVELOPMENTS. AS A REMINDER, YOU ARE CHARGED WITH KNOWLEDGE OF THE CONTENT ON VIRTUAL UNDERWRITER  AS IT EXISTS FROM TIME TO TIME AS IT APPLIES TO YOU, AS WELL AS ANY OTHER INSTRUCTIONS. OUR UNDERWRITING AGREEMENTS DO NOT AUTHORIZE OUR ISSUING AGENTS TO ENGAGE IN SETTLEMENTS OR CLOSINGS ON BEHALF OF STEWART TITLE GUARANTY COMPANY. THIS BULLETIN IS NOT INTENDED TO DIRECT YOUR ESCROW OR SETTLEMENT PRACTICES OR TO CHANGE PROVISIONS OF APPLICABLE UNDERWRITING AGREEMENTS. CONFIDENTIAL, PROPRIETARY, OR NONPUBLIC PERSONAL INFORMATION SHOULD NEVER BE SHARED OR DISSEMINATED EXCEPT AS ALLOWED BY LAW. IF APPLICABLE STATE LAW OR REGULATION IMPOSES ADDITIONAL REQUIREMENTS, YOU SHOULD CONTINUE TO COMPLY WITH THOSE REQUIREMENTS.

References

Bulletins Replaced:
None
Related Bulletins:
NY000578 US Department of Treasury: Financial Crimes Enforcement Network (FinCEN) Geographic Targeting Order, New York County, NY and Miami-Dade County Florida
Underwriting Manual:
None
Exceptions Manual:
None
Forms:
None