Informational only. Always verify at FinCEN.gov before making compliance decisions. Last refreshed: 2026-10-14.
“The Boroughs of Manhattan (New York County), Brooklyn (Kings County), Queens (Queens County), the Bronx (Bronx County), and Staten Island (Richmond County), New York”
Threshold
$300,000
Effective
December 1, 2024
Expires
February 28, 2026
Geography
county
This GTO - covering all five NYC boroughs and requiring title insurance companies to report beneficial ownership of legal entities in all-cash residential purchases of $300,000 or more - was superseded on March 1, 2026 when FinCEN's nationwide residential real estate reporting rule took effect.
Formal Geographic Text (from order)
“The Boroughs of Manhattan (New York County), Brooklyn (Kings County), Queens (Queens County), the Bronx (Bronx County), and Staten Island (Richmond County), New York”
All five NYC boroughs. FIPS: 36061 (Manhattan), 36047 (Brooklyn), 36081 (Queens), 36005 (Bronx), 36085 (Staten Island).
Who Must Report
Title insurance companies
What Must Be Reported
Beneficial ownership of legal entities making all-cash residential real estate purchases at or above $300,000; file a FinCEN Currency Transaction Report via BSA E-Filing System within 30 days of closing
Threshold
$300,000
All-cash transactions at or above
Source Agency
FinCEN
FinCEN order PDF | FinCEN news release
Renewed covering all five NYC boroughs at $300K threshold.
Superseded by FinCEN nationwide residential real estate reporting rule effective March 1, 2026.
Renewal Chain
Common questions about this specific GTO, with answers grounded in the official order text.
These answers are for informational purposes only and are grounded in the official FinCEN order text. They do not constitute legal advice.
Analyst Notes
Expanded from Manhattan-only (2016) to all five boroughs. Superseded by FinCEN's permanent nationwide rule (March 1, 2026). See https://www.fincen.gov/rre.
Soflo Consulting
We offer risk assessments, AML policy creation, and AML program reviews & gap analysis for businesses operating in FinCEN GTO-covered jurisdictions.
