FinCEN rules, state rate cuts reshape title insurance in 2025
Briefly

FinCEN rules, state rate cuts reshape title insurance in 2025
"The GTOs (FinCEN's geographic targeting orders) came in 2017. They started off kind of slow five boroughs in New York and a few counties in Florida. Fast forward to the current GTO, it affects transactions in 11 states, plus Washington, D.C., and about 58 or 59 counties or boroughs. The FinCEN reporting that is now going to be required is all 50 states plus the District of Columbia, about 3,600 recording jurisdictions. That gives you the magnitude of how much this will impact the industry."
"The FinCEN reporting is required for settlement agents anybody that's closing a real estate transaction. That means title companies, private escrow companies, some law firms, anybody doing the settlement. They started off those GTOs on high dollar amounts $3 million, $5 million. Under the current GTO, the threshold is $300,000. With the new rule, it drops to zero. You have to report on the first dollar."
Geographic targeting orders began in 2017 and gradually expanded from a few New York boroughs and Florida counties to cover transactions in 11 states plus Washington, D.C., and roughly 58–59 counties or boroughs. FinCEN reporting will now apply to all 50 states and the District of Columbia, covering about 3,600 recording jurisdictions. Reporting responsibility rests with settlement agents, including title companies, private escrow companies, and some law firms. Reporting thresholds fell from multi‑million dollar levels to $300,000 under the current GTO and will drop to zero under the new rule, requiring reporting on the first dollar. The rule is effective Dec. 1, with reporting required beginning March 1, 2026, and significant confusion remains in regions new to FinCEN reporting.
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