© 2025 Alliant National Title Insurance Company
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TO:
Alliant National Colorado, District of Columbia, Florida, Illinois, Maryland, Nevada,
Texas, and Virginia Agents
DATE:
April 15, 2025
SUBJECT:
FinCEN Geographic Targeting Order Effective April 15, 2025
The Financial Crimes Enforcement Network (“FinCEN”) of the United States Department of the Treasury has
extended its Geographic Targeting Orders (“GTO’s”) requiring Alliant National and its agents to collect and report
information on certain residential real estate purchases in specifically identified cities and counties through
October 9, 2025. See attached copy. All previously identified geographic locations remain the same, without
any additions or deletions.
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nless renewed or otherwise extended, the new GTO expires on October 9, 2025, for all identified
geographic locations. The new GTO still imposes the same potential civil and criminal penalties for
noncompliance by Alliant National or its agents.
A
s with the prior GTOs, “Covered Transactions” must be reported. A “Covered Transaction” is one in which:
1) The pur
chase price is either $300,000 or more; or $50,000 or more if the property is located in either
the City or County of Baltimore, Maryland.
2) The pr
operty is located in one of the following states, and its counties or cities:
State
Counties
Cities
District of
Columbia
Colorado
Adams
Arapahoe
Clear Creek
Denver
Douglas
Eagle
Elbert
El Paso
Fremont
Jefferson
Mesa
Pitkin
Pueblo
Summit
Florida
Broward
Miami-
Dade
Palm Beach
Hillsborough
Pasco
Pinellas
Manatee
Sarasota
Charlotte
Lee
Collier
Illinois
Cook
Maryland
Anne
Arundel
Howard
Montgomery
Prince
George’s
Baltimore
Baltimore
Nevada
Clark
Texas
Bexar
Dallas
Tarrant
Harris
Montgomery
Webb
Travis
Virginia
Arlington
Fairfax
Alexandria
Falls
Church
Fairfax
3) The pr
operty is residential;
4) The pur
chase is made without a bank loan or other similar form of external financing (hard money
loans are non-institutional so they do not qualify as bank loans);
MULTISTATE UNDERWRITING BULLETIN
25-50 (CO, DC, FL, IL, MD, NV, TX, VA)
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5) The pur
chaser is a “Legal Entity” (a corporation, limited liability company, partnership, or other similar
business entity, whether formed under the laws of a state in the U.S. or a foreign jurisdiction; this term
no longer includes Trusts or Trustees of Trusts); and
6) The purchase is made, at least in part, using currency or a cashier’s check, a certified check, a
traveler’s check, a personal check, a business check, or a money order in any form, a funds transfer
(wired funds), or virtual currency.
For
a Covered Transaction, the GTO requires that certain information be reported on FinCEN’s Currency
Transaction Report. This information includes:
1) The i
dentity of the Purchaser (the Legal Entity that is purchasing the residential real estate in a Covered
Transaction);
2) The identity of the “Beneficial Owners” of the Legal Entity (defined as each individual who directly or
indirectly owns 25% or more of the equity interests in a corporation, partnership or other business entity;
and
3) The i
dentity of the person primarily responsible for representing the Purchaser.
A
ll Alliant National search reports/commitments involving any land in the above-referenced states and counties
must include the following requirement in Schedule B for Colorado, the District of Columbia, Florida, Illinois,
Maryland, Nevada, Virginia, and in Schedule C for Texas:
State / Schedule
Language for Requirement
Colorado, on Schedule
B
When 1) the land is residential real property and is located in Adams,
Arapahoe, Clear Creek, Denver, Douglas, Eagle, Elbert, El
Paso, Fremont,
Jefferson, Mesa, Pitkin, Pueblo, and Summit counties, Colorado; 2) the total
purchase price is $300,000 or more; 3) the purchase is made without a loan
from a financial institution; and 4) the purchaser is a corporation, limited
liability company, partnership, or other business entity, the Title Agent must
provide the Company with the information required by the FinCEN Geographic
Targeting Order dated April 14, 2025 or any renewal thereof.
District of Columbia, on
Schedule B
When 1) the land is residential real property and is located in the District of
Columbia; 2) the total purchase price is $300,000 or more; 3) the purchase is
made without a loan from a financial institution; and 4) the purchaser is a
corporation, limited liability company, partnership, or other business entity,
the Title Agent must provide the Company with the information required by
the FinCEN Geographic Targeting Order dated April 14, 2025 or any renewal
thereof.
Florida, on Schedule B
When 1) the land is residential real property and is located in Broward, Miami-
Dade, Palm Beach
, Hillsborough, Pasco, Pinellas, Manatee, Sarasota,
Charlotte, Lee or Collier counties, Florida
; 2) the total purchase price is
$300,000 or more; 3) the purchase is made without a loan from a financial
institution; and 4) the purchaser is a corporation, limited liability company,
partnership, or other business entity, the Title Agent must provide the
Company with the information required by the FinCEN Geographic Targeting
Order dated April 14, 2025 or any renewal thereof.
Illinois, on Schedule B
When 1) the land is residential real property and is located in Cook county,
Illinois; 2) the total purchase price is $300,000 or more; 3) the purchase is
made without a loan from a financial institution; and 4) the purchaser is a
corporation, limited liability company, partnership, or other business entity,
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the Title Agent must provide the Company with the information required by
the FinCEN Geographic Targeting Order dated April 14, 2025 or any renewal
thereof.
Maryland, on Schedule
B
When 1) the land is residential real property and is located in Anne Arundel,
Howard, Montgomery, or Prince George’s counties, Maryland; and the total
purchase price is $300,000 or more; or 2) the land is residential real property
and is located in the city or county
of Baltimore, Maryland, and the total
purchase price is $50,000 or more; and 3) the purchase is made without a loan
from a financial institution; and 4) the purchaser is a corporation, limited
liability company, partnership, or other business entity, the Title Agent must
provide the Company with the information required by the FinCEN Geographic
Targeting Order dated April 14, 2025 or any renewal thereof.
Nevada, on Schedule B
When 1) the land is residential real property and is located in Clark county,
Nevada; 2) the total purchase price is $300,000 or more; 3) the purchase is
made without a loan from a financial institution; and 4) the purchaser is a
corporation, limited liability company, partnership, or other business entity,
the Title Agent must provide the Company with the information required by
the FinCEN Geographic Targeting Order dated April 14, 2025 or any renewal
thereof.
Texas, on Schedule C
When 1) the land is residential real property and is located in Bexar, Dallas,
Tarrant, Harris, Montgomery, Travis or Webb
counties, Texas; 2) the total
purchase price is $300,000 or more; 3) the purchase is made without a loan
from a financial institution; and 4) the purchaser is a corporation, limited
liability company, partnership, or other business entity, the Title Agent must
provide the Company with the information required by the FinCEN Geographic
Targeting Order dated April 14, 2025 or any renewal thereof.
Virginia, on Schedule B
When 1) the land is residential real property and is located in Arlington or
Fairfax counties, Virginia; or located in the cities of Alexandria, Falls Church
or Fairfax; 2) the total purchase price is $300,000 or more; 3) the purchase is
made without a loan from a financial institution; and 4) the purchaser is a
corporation, limited liability company, partnership, or other business entity,
the Title Agent must provide the Company with the information required by
the FinCEN Geographic Targeting Order dated April 14, 2025 or any renewal
thereof.
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pon request, purchaser must provide certain required information to the Title Agent prior to closing.
Please
refer to the GTO Questionnaire and GTO Information Gathering Form to assist you in determining
whether a transaction is a Covered Transaction and how to report a Covered Transaction.
CLICK HERE to download the GTO Questionnaire.
CLICK HERE to download the GTO Information Gathering Form.
As a courtesy to our Title Agents, Alliant National will prepare and submit the required FinCEN filing for
you upon your submission to us of the completed GTO Questionnaire, GTO Information Gathering Form,
and legible photo-copies of government-issued identification for the parties involved in the Covered
Transaction. Please deliver these documents to us no later than 5 days after closing via our secure electronic
portal, accessible from our Agent Resource Center (for which you will need your user name and password to
enter), and then click on the tab called “Resource Center,” and select “FinCEN” from the drop-down menu. That
will take you to a webpage from which you can download the above-referenced forms, and into which you can
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drag the forms, once completed, to upload to Alliant National. To assist you in properly preparing these forms
and submitting the information to us, please refer to our tutorial for detailed instructions and depictions.
CLICK HERE to download the Compliance Tutorial.
If you have elected to prepare and submit the required FinCEN filing, yourself, via the BSA E-Filing
System, then please provide us with a copy of the CTR 112 Report and photo-copies of government-
issued identification for the parties involved in the Covered Transaction. Our secure electronic portal,
accessible via the Agent Resource Center (as described above), should also be used for this transmission in
order to protect Non-Public Personal Information (NPI).
If you have difficulty accessing the secure electronic portal, or have any questions, please contact our Regulatory
Compliance Officer, Elyce Schweitzer, at eschweitzer@alliantnational.com, or phone (303)682-9800, ext. 415,
for assistance.
The GTO requires both Alliant National and its agents to retain copies of all records for a period of five
(5)
year
s after April 14, 2025 or longer if the GTO is renewed or otherwise extended. This is an extension
of the prior GTO. To meet this requirement, you will need to keep copies of the completed GTO Questionnaires,
and
for Covered Transactions, copies of the GTO Information Gathering Forms and photo ID’s of all parties
shown on that form.
As always, please contact us with any questions or comments.
