Question 1

Is there a FinCEN Geographic Targeting Order (GTO) in Miami-Dade, Broward, Palm Beach (FL), NYC 5 Boroughs (NY), Los Angeles, San Diego, SF Bay Area (CA)?

Accepted Answer

There was previously a FinCEN GTO covering Specific counties and jurisdictions across California, Colorado, Connecticut, Florida, Georgia, Hawaii, Illinois, Maryland, Massachusetts, Nevada, New York, Texas, Virginia, Washington, and the District of Columbia. The order is currently superseded. Phase 20 was the final residential real estate GTO, effective October 10, 2025 through February 28, 2026. FinCEN issued it on October 9, 2025 as a bridge measure because the compliance date for the permanent nationwide Residential Real Estate Reporting Rule was set to March 1, 2026. Coverage was identical to Phase 19 - the same counties across 14 states and DC - with the same $300,000 reporting threshold ($50,000 for Baltimore City and County). On March 1, 2026, the permanent nationwide rule took effect and all Phase 20 obligations were replaced.

Question 2

What is the reporting threshold for the Miami-Dade, Broward, Palm Beach (FL), NYC 5 Boroughs (NY), Los Angeles, San Diego, SF Bay Area (CA) GTO?

Accepted Answer

The reporting threshold for this GTO is $300,000. Title insurance companies and their agents in covered counties must report beneficial ownership information for legal entities purchasing residential real property for $300,000 or more in all-cash transactions within the covered jurisdiction.

Question 3

Who must comply with the FinCEN GTO in Miami-Dade, Broward, Palm Beach (FL), NYC 5 Boroughs (NY), Los Angeles, San Diego, SF Bay Area (CA)?

Accepted Answer

Title insurance companies and their agents in covered counties operating in Specific counties and jurisdictions across California, Colorado, Connecticut, Florida, Georgia, Hawaii, Illinois, Maryland, Massachusetts, Nevada, New York, Texas, Virginia, Washington, and the District of Columbia must comply with this GTO. Specifically, they must: Beneficial ownership of legal entities and certain trusts making all-cash residential real estate purchases at or above $300,000 ($50,000 for Baltimore); file a FinCEN Currency Transaction Report via BSA E-Filing System within 30 days of closing. Effective: October 10, 2025 – February 28, 2026..

Question 4

When did the Miami-Dade, Broward, Palm Beach (FL), NYC 5 Boroughs (NY), Los Angeles, San Diego, SF Bay Area (CA) FinCEN GTO take effect?

Accepted Answer

This GTO became effective on 2025-10-10. It is set to expire on 2026-02-28.

Question 5

Where can I find the official FinCEN order for Miami-Dade, Broward, Palm Beach (FL), NYC 5 Boroughs (NY), Los Angeles, San Diego, SF Bay Area (CA)?

Accepted Answer

The official source for this GTO is available at https://www.fincen.gov/news/news-releases/fincen-renews-residential-real-estate-geographic-targeting-orders. The order PDF can be downloaded directly from https://www.fincen.gov/system/files/2025-10/Phase-20-GTO-Order-FINAL-508.pdf. Always verify current GTO status directly with FinCEN before making compliance decisions.

Residential Real Estate Geographic Targeting Orders - Phase 20 (October 10, 2025 - February 28, 2026)

Order Summary

Geographic Coverage

Reporting Requirements

Change Log

Frequently Asked Questions

Other GTOs in FL

Quick Facts

Official Sources

Covered Industries

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