What are GTOs and how do they affect the real estate market? 

They are a tool used by the Financial Crimes Enforcement Network (FinCEN) with the goal of identifying the natural people behind the companies used in residential real estate purchases in specific geographic areas. 

GTOs are issued for a limited period of time and cover certain counties within major U.S. metropolitan areas, such as Boston, Chicago, Los Angeles, Miami, New York, San Francisco and Seattle, among others. The purchase threshold varies by area, but is usually $300,000, except for Baltimore City and County, where the threshold is $50,000. 

When should I report it? 

GTO reports must be made within the following 30 days of the closing date of the transaction. They must be sent to FinCEN using Form 8300, which can be completed and electronically submitted through the BSA E-Filing system. 

It must include the following information: 

• The identification data of the legal entity purchasing the property, including name, address, tax identification number and type of entity. 
• Identification data of the beneficial owners of the legal entity purchasing the property, including name, date of birth, address and personal identification number (such as social security number or passport). 
• The identification data of the person representing the legal entity purchasing the property, including name, address, phone number and e-mail address. 
• The identification data of the person receiving payment for the sale of the property, including name, address and tax identification number. 
• The identification data of the property title insurance company involved in the transaction, including name, address, phone number and e-mail address. 
• Transaction data, including the amount, date, type and number of monetary instruments used for payment, as well as the description and location of the property. 

What happens if I don't report it? 

Failure to comply can result in civil and criminal penalties for both property title insurance companies as well as individuals involved in transactions related to the GTOs. 

Civil penalties can be up to $1,000,000 and criminal penalties can be up to 5 years in prison. 

To avoid these penalties, it is important that individuals and companies that make real estate purchases seek information and comply with all their obligations. This helps to protect the real estate market from corruption and crime and promotes a fairer and more transparent economy.