Bulletin: NY000581

Date:
March 01, 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 a reminder the reporting requirement begins today, 3/1/2016.  We had previously advised you to add a requirement to your title reports/commitments about the reporting requirements. To assist in this reporting, and in our continuing efforts to advise you on this matter, attached please find an amended requirement, and a GTO certification form to be used at or prior to closing.  Stewart suggests that this form be required on all residential transactions in New York County (Manhattan) where the purchase price exceeds the three million dollar ($3,000,000.00) limit for a covered transaction (residential real property purchased by a legal entity, where all or a portion of the purchase price is made in case as defined in the GTO without institutional financing). This form is available in a Print-and-Write form and a Fill-In form.  In addition to being attached to this bulletin, it will also be available to download from our web site. 

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

Forms: IRS/FinCEN 8300; Cert Fill-In; Cert Print and Write

Attachments: FinCEN Updated Requirements; Frequently asked Questions; ALTA Fact Sheet; First Calls Schedule

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.