In the last few weeks, Financial Crimes Enforcement Network (FinCEN) announced the renewal of its Geographic Targeting Orders which requires the natural person owners of entities purchasing residential real estate without loans. This is consistent with BOIR filing requirement under Corporate Transparency Act and is a reminder that anyone buying residential properties via LLCs. The announcement indicates it only applies (i) in certain areas, (ii) for purchase prices over $300K in most areas and (iii) $50,000 in Baltimore. (Final Rule Here)

Investors and buyers of real estate should be prepared to provide organizational documents and certifications to title insurance companies for new residential cash purchases