Question 1

Is there a FinCEN Geographic Targeting Order (GTO) in San Francisco County, San Mateo County, Santa Clara County?

Accepted Answer

There was previously a FinCEN GTO covering San Francisco County, San Mateo County, Santa Clara County, Alameda County, and Contra Costa County, California. The order is currently superseded. This GTO covering five San Francisco Bay Area counties was superseded on March 1, 2026 by FinCEN's nationwide residential real estate reporting rule, which replaced all geographic targeting orders with a permanent nationwide program.

Question 2

What is the reporting threshold for the San Francisco County, San Mateo County, Santa Clara County GTO?

Accepted Answer

The reporting threshold for this GTO is $300,000. Title insurance companies 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 San Francisco County, San Mateo County, Santa Clara County?

Accepted Answer

Title insurance companies operating in San Francisco County, San Mateo County, Santa Clara County, Alameda County, and Contra Costa County, California must comply with this GTO. Specifically, they must: 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.

Question 4

When did the San Francisco County, San Mateo County, Santa Clara County FinCEN GTO take effect?

Accepted Answer

This GTO became effective on 2024-12-01. It is set to expire on 2026-02-28.

Question 5

Where can I find the official FinCEN order for San Francisco County, San Mateo County, Santa Clara County?

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-0. The order PDF can be downloaded directly from https://www.fincen.gov/system/files/2024-10/Phase-19-Order-FINAL-508.pdf. Always verify current GTO status directly with FinCEN before making compliance decisions.

Geographic Targeting Order - San Francisco Bay Area, California (Real Estate) 2024

Order Summary

Geographic Coverage

Reporting Requirements

Change Log

Frequently Asked Questions

Other GTOs in CA

Quick Facts

Official Sources

Covered Industries

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