The Washington Report

April 22, 2024

In This Issue

Money Laundering and Terrorism Financing
FinCEN Renews Its Geographic Targeting Orders (GTOs)
NAR Submits Comment on FinCEN Proposed Rule

Private Property Rights
NAR Property Rights Wins at Supreme Court

 

Money Laundering and Terrorism Financing


FinCEN Renews Its Geographic Targeting Orders (GTOs)

This week, the Financial Crimes Enforcement Network (FinCEN) renewed its Geographic Targeting Orders (GTOs) requiring U.S. title companies to identify and report information regarding beneficial owners when companies are used to purchase residential real estate. The current GTO is effective beginning April 19, 2024, until October 15, 2024. FinCEN renewed the GTOs in the current states California, Colorado, Connecticut, Florida, Hawaii, Illinois, Maryland, Massachusetts, Nevada, New York, Texas, Washington, Virginia, and the District of Columbia. The purchase amount that triggers reporting under the GTO is $300,000 for most jurisdictions and $50,000 in the greater Baltimore region. FinCEN also issued updated FAQs regarding the GTOs as well. 

NAR will continue to keep you updated regarding the GTOs and FinCEN updates. 

Learn more about the current GTO

Nia Duggins, nduggins@nar.realtor, 202-383-1085

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Money Laundering and Terrorism Financing


NAR Submits Comment on FinCEN Proposed Rule

This week, NAR submitted a formal comment on the Financial Crime Enforcement Network’s (FinCEN) notice of proposed rulemaking regarding Anti-Money Laundering Regulations for Residential Real Estate Transfers. FinCEN, with this proposed rule, is seeking to develop a more formal framework for tracking and reporting non-financed, all-cash residential real estate transactions with the goal of eliminating the Geographic Targeting Orders (GTOs), which have been in place since 2016. Additionally, FinCEN is seeking to work to effectively combat money laundering and illicit financial crimes involving real estate. The proposed rule outlines a cascading reporting mechanism where settlement agents, title agents, and attorneys would be primarily responsible for filing new “Real Estate Reports” with FinCEN. While NAR believes that a predictable and consistent framework is needed, NAR remains concerned about the cost of compliance for this proposed rule, and that the rule is too broad in scope by requiring the reporting of transfers of real estate that are not likely high risk in nature in any way.

NAR also recently met with the Treasury Department along with industry stakeholder to discuss this rule. NAR supports risk-based and pragmatic solutions to combat money laundering and illicit financing involving real estate.

NAR will continue to provide updates regarding anti-money laundering developments.

Read NAR's comment letter to FinCEN.

Nia Duggins, nduggins@nar.realtor, 202-383-1085

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Private Property Rights


NAR Property Rights Wins at Supreme Court

In the span of just a few days, NAR and property owners won two decisive victories at the Supreme Court in support of property rights. On Friday, April 12, the U.S. Supreme Court ruled unanimously (9-0) in support of property owners in Sheetz v. El Dorado County, and on Tuesday, April 16, they once again ruled unanimously in favor or property rights in DeVillier v. Texas. NAR submitted amicus briefs in support of upholding property rights for both cases.

In Sheetz, the plaintiff sued the state of California arguing that a traffic impact mitigation fee being imposed by the state before he could build a home on his own property was a “taking” under the Constitution’s Fifth Amendment “takings clause,” which requires the government to pay just compensation when acquiring property from private owners for public use. The property owner argued that a “takings” test (Nollan/Dolan), previously established by Supreme Court cases which applied to fees imposed on an individual basis, was relevant in this case—while the state argued that because the fees came from legislation, it did not. The court agreed with the plaintiff, holding that the test to determine if a takings has occurred can be applied to fees authorized by legislation as well.  

In Devillier, the case revolved around private properties that were flooded when Texas took actions to use portions of a nearby highway as a flood evacuation route, installing a barrier along the way to act as a dam. The result was flooding of private property on the other side of the erected barrier, causing significant damage. The plaintiff argued that by building the barrier and using his property to store stormwater, the state had effected a taking on his property and owed him just compensation. The court held that the plaintiff was able to pursue a takings clause case through a cause of action under Texas state law.

NAR’s work to support property rights in both these cases demonstrates its commitment to advocating for private property rights not just in the legislative and regulatory sphere, but also in the judicial system, up to the highest court in the land. They establish important precedents that will be used in future legal arguments to protect private property rights in this country.

Read about NAR's amicus briefs on the cases.

Russell Riggs, rriggs@nar.realtor, 202-383-1259

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