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#2239748 - 07/17/20 02:19 PM FinCEN Geographic Targeting Order Clarification
BSA2019 Offline
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Joined: Mar 2019
Posts: 17
Is there an obligation for Banks to research customer base and make sure Title Insurance Company customers are abiding by GTOs? What if none of the customers are located in the counties listed in the GTO?

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#2239757 - 07/17/20 03:42 PM Re: FinCEN Geographic Targeting Order Clarification BSA2019
rlcarey Offline
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rlcarey
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Galveston, TX
It is the title company's total responsibility. It is based on the location of the property and not the borrowers.
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#2239769 - 07/17/20 04:46 PM Re: FinCEN Geographic Targeting Order Clarification BSA2019
BSA2019 Offline
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Posts: 17
Thank you. Are other FIs researching their customer bases and making sure the Title companies are aware of the GTO?

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#2239771 - 07/17/20 05:13 PM Re: FinCEN Geographic Targeting Order Clarification BSA2019
rlcarey Offline
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rlcarey
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Galveston, TX
Not sure why you would?? Why do you care?
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#2239831 - 07/20/20 02:53 PM Re: FinCEN Geographic Targeting Order Clarification BSA2019
John Burnett Offline
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John Burnett
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Cape Cod
Should banks be aware there is a GTO in effect in their area? Yes. Knowing about GTOs can put a bank on alert for persons purchasing multiple cashier's checks or for a series of seemingly unrelated cashier's checks presented on the same day that might appear to be involved in the same financial transaction (all indorsed by the same title company, for example, after indorsements by apparently unrelated or disconnected payees).

Otherwise, I agree with Randy Carey -- You don't need to concern yourself with notifying customers who might be title companies or verify that they are complying. FinCEN has taken pains to ensure that title companies serving the metro areas covered by the GTOs know what's happening. After all, there have been GTOs in effect off and on in the affected areas for a long time. It's old news.

Or don't you have enough to do already in the BSA/AML arena? wink
Last edited by John Burnett; 07/22/20 07:47 PM.
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John S. Burnett
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