eqAGNr9o6V$)/\Y}?l06s@(t5sc1#9Gc6:K5Se`M#_=(L[g!=3R25I8 jI=ZZM,R2w7\qf~k-)2 d'}NJaDY#$. 27. United States 5326(a). Should FinCEN require information regarding the source of funds used to purchase real estate? https://www.nar.realtor/newsroom/existing-home-sales-recede-2-0-in-august 315;ing out the purposes of this chapter. FinCEN recognizes the potential for non-financed purchases by natural persons to facilitate money laundering and other illicit activity. The Public Inspection page In contrast to FinCEN's use of Real Estate GTOs to focus on all-cash transactions involving residential real estate, FinCEN decided at the time not to impose a reporting requirement on all cash commercial real estate transactions. 51. v. Div. Va. Feb. 26, 2018) (purchase of a property in Virginia); These markup elements allow the user to see how the document follows the A SYDNEY property developer has scored himself a free $1.7 million home by simply moving in and renting it out following the death of the occupant. Section 32 of the Property and Stock Agents Act 2002 ('the Act') sets out the requirements for a licensee to properly supervise the business carried on by that licensee. Such a specific reporting requirement could be imposed under 31 U.S.C. At the same time, FinCEN recognizes that an iterative approach may be warranted given the complexities and differences between different market sectors and the potential burdens that new reporting and recordkeeping requirements may have for businesses. See, e.g., [66] This count refers to the total comment/submissions received on this document as reported by Regulations.gov (last updated on 02/28/2023 at 12:35 pm). Advisory to Financial Institutions and Real Estate Firms and Professionals, Financial Crimes Enforcement Network, FIN-2017-A003 (Aug. 22, 2017). This table of contents is a navigational tool, processed from the Bradley, Section 32 - vendor's statement The seller and their legal practitioner or conveyancer usually complete this statement, which must be provided to a prospective buyer before they sign the contract of sale. https://thesentry.org/about/. It is unclear whether such a transaction would be viewed to be a cash transaction from the point of view of the entities required to report such a transaction. Additionally, FinCEN seeks specific comment on whether to include trustsbroadly defined as a legal relationship in which one person holds title to property, subject to an obligation to keep or use the property for the benefit of anotherwithin the reporting the current document as it appeared on Public Inspection on Although a significant portion of those residential real estate transactions are financed by regulated RMLOs, GSEs, and depository institutions, non-financed real estate transactions can largely avoid financial institutions that are subject to AML/CFT requirements. 4. FinCEN understands from various law enforcement agencies that the Real Estate GTO data has been highly useful to the investigation of money laundering and financial crimes. The annualized transfer over the 10-year period was $118.05 million and $119.27 million at discount rates of 3 and 7 percent, respectively. 51. Raul Torres, The BSA also requires each financial institution to establish AML/CFT programs, including, at a minimum, (A) the development of internal policies, procedures, and controls; (B) the designation of a compliance officer; (C) an ongoing employee training program; and (D) an independent audit function to test programs.[24] FinCEN also explained its concern that many of these financial institutions were sole proprietors or small businesses, and FinCEN intended to avoid imposing unreasonable regulatory burdens with little or no corresponding anti-money laundering benefits.[30]. 77. 58. Public Law 107-56, Title III, Sec. Should FinCEN require reports from multiple financial institutions or nonfinancial trades or businesses involved in a non-financed purchase of residential real estate, or should FinCEN propose a reporting requirement via a cascading hierarchy based on the types of entities involved in a particular transaction, as is the case for IRS Form 1099-S? 63. United States The Company has filed with the Securities and Exchange Commission (the "Commission") and the Commission has declared effective, in accordance with the provisions of the Securities Act, a registration statement on Form S-3 (File No. 2005) (purchase of two properties in North Carolina); 8. How do due diligence processes, if any, differ for commercial or residential properties? Real Estate Institute of New South Wales - RTO Number: 90117 (Registered Training Organisation), We would love your feedback. 17. Instead, all-cash real estate transactions may involve only relatively small businesses or individuals involved in closing and settlement, and the participants may lack financial incentives to closely monitor the nature of the transactions. 2. Delgado, 1 (D. MD Jul. The report further highlighted the use of shell companies and trusts to obscure the true owners of the properties.[18]. 2:18-cr-00103-RDP-JEO, Doc. 26. 10. (g) the property, or is part of, a building where a development application or complying development certificate application has been lodged under the Environmental Planning and Assessment Act 1979 for rectification of the building regarding external combustible cladding. 34. the material on FederalRegister.gov is accurately displayed, consistent with See generally Should FinCEN's proposed rule be limited to residential real estate or should FinCEN cover transactions involving other forms of real estate ( Moreover, data on real estate purchases is held in a patchwork of different state and county databases, making investigation and analysis difficult. Because such activity can occur in any location, limiting the scope of the regulations by geography may simply push money laundering activity into other locations. In its 2006 and 2011 reports, FinCEN detailed various types of suspicious transactions indicative of money laundering in the commercial real estate industry. 16. Please describe any best practices related to due diligence on the seller and buyer of residential or commercial real estate; confirmation of the legality of the transaction; inquiries as to the source of acquisition funding; and any other issues that may relate to the marketing, negotiation of terms, and closing of the transaction. 31 U.S.C. ; Monthly New Residential Sales, August 2021, U.S. Census Bureau, Release CB21-155 (Sep. 24, 2021), Menu Home; Rankings. Properly supervise persons engaged in the business. FinCEN invites comments regarding the approach that it should take with respect to regulatory treatment of residential and commercial real estate and the money laundering threats presented by these sectors. FinCEN is considering, and invites comments on, such an approach. 0000004126 00000 n It is not an official legal edition of the Federal 1829b, 12 U.S.C. If an iterative approach is warranted, FinCEN could initially focus on residential real estate followed by additional action to promulgate regulations covering the commercial real estate sector, as well as any other regulatory gaps that may exist with money laundering vulnerabilities involving real estate. 188 A.3d 1009 (MD Ct. App. FinCEN therefore invites comment through this ANPRM on appropriate regulatory frameworks to do so, including possible nationwide recordkeeping and reporting requirements pursuant to 31 U.S.C. documents in the last year. regulatory information on FederalRegister.gov with the objective of This requirement includes supervising employees and establishing and monitoring compliance procedures. Moreover, one study found that the Real Estate GTOs had the added ameliorative effect of decreasing anonymous capital flows into the U.S. housing markets, thereby lessening the overall likelihood of BSA evasion via the real estate sector. [46] If program or other requirements were limited to purchases above a certain price threshold, how would this impact: (i) The burden of implementing such potential rules; and (ii) the utility of such potential rules for addressing money laundering issues in the real estate market? 1:20-cv-23278, Doc. Would certain businesses incur higher costs compared to others? Bradley, These areas are: (1) The Texas counties of Bexar (includes San Antonio), Tarrant, and Dallas; (2) the Florida counties of Miami-Dade, Broward, and Palm Beach; (3) all New York City boroughs: Brooklyn, Queens, Bronx, Staten Island, and Manhattan; (4) the California counties of San Diego, Los Angeles, San Francisco, San Mateo, and Santa Clara; (5) the City and County of Honolulu in Hawaii; (6) the Nevada county of Clark (includes Las Vegas); (7) the Washington county of King (includes Seattle); (8) the Massachusetts counties of Suffolk and Middlesex (includes Boston and Cambridge, respectively); and (9) the Illinois county of Cook (includes Chicago). 4. How should FinCEN define commercial real estate? 29, 2007); United States Its important to be mindful of the consequences that may flow from failure to comply with the Supervision Guidelines. The Property, Stock and Business Agents Act 2002 contains requirements relating to the keeping of records under that Act. https://www.census.gov/construction/nrs/pdf/quarterlysales.pdf. and services, go to Miller, Describe a typical residential real estate transaction. Dealing with licences Serious offences We will cancel your licence if you're convicted of: violent offences (including threats to use violence) fraud or dishonesty offences drug trafficking extortion arson unlawful stalking an offence of a sexual nature. However, while there are certainly many similarities in terms of policies and procedures from agency to agency, there will also be some differences. Click on the "Check for Amendments ." link for amendments since consolidation. The Secretary of the Treasury (Secretary) has delegated to the Director of FinCEN the authority to implement, administer, and enforce compliance with the BSA and associated regulations. see also Describe the potential money laundering and illicit finance risks and vulnerabilities arising in the U.S. real estate market. 57. 78. Finally, it's done: an article about the Haut de la Garenne child abuse case. C. Which real estate transactions should FinCEN's rule cover? Real Property Located in Potomac, Maryland, Commonly Known as 9908 Bentcross Drive, Potomac, MD 20854, 2005) (transaction under $50,000). [8] . 10.10 Acres Located on Squires Rd., documents in the last year, 522 real estate transactions without financing by a bank, RMLO, or GSE), which represent approximately 20% of real estate sales. and the orders now cover all U.S. title insurance companies operating in those areas. 5312(a)(2)(U). Initially title insurances companies reported GTO information to FinCEN via FinCEN Form 8300 (Report of Cash Payments Over $10,000 Received in a Trade or Business). 0000001366 00000 n See, e.g., United States The result is an opaque field full of diverse foreign and U.S. domiciled legal entities associated with transactions worth hundreds of millions Real Property Located in Potomac, Maryland, Commonly Known as 9908 Bentcross Drive, Potomac, MD 20854, . It was viewed 59 times while on Public Inspection. 3:15-cr-00037-2, 2019 U.S. Dist. For purposes of the Real Estate GTOs, residential real property means real property (including individual units of condominiums and cooperatives) designed principally for the occupancy of from one to four families. In a 2014 final rule, FinCEN extended similar requirements to the housing-related Government Sponsored Enterprises (GSEs)Fannie Mae, Freddie Mac, and the Federal Home Loan Banks. 26 CFR 1.6045-4. electronic version on GPOs govinfo.gov. LLC as Rights Agent (incorporated herein by reference to to Exhibit 4.1 of the Company's Form 8-K filed on November 14, 2022) . 1951-1960, 31 U.S.C. This requirement includes supervising employees and establishing and monitoring compliance procedures. 31 U.S.C. 559 F.3d 303 (5th Cir. A uniform national requirement would also provide consistency and predictability to businesses required to maintain records and make reports. Later Real Estate GTOs changed the parameters of Covered Transactions to include new geographic areas, modify the reporting threshold, and cover additional payment methods. documents in the last year, 287 15. Atty. v. documents in the last year, by the Rural Utilities Service See generally 52. Vandana Ajay Kumar, Money Laundering: Concept, Significance and its Impact, European Journal of Business and Management, p. 117 (Vol 4 No. Unlicensed property agent work is against the law. What general factors should FinCEN consider in determining the scope of such a rule? While a PDF of the Manual can be downloaded and printed, REINSW does not recommend it. Generally, the Census Bureau tracks new home sales, while the most accurate data for existing home sales is generated by NAR. What are the key benefits for a particular stakeholder ( v. FinCEN received 52 comments on the 2003 ANPRM from individuals, various institutions and associations of interested parties, law firms, state bar associations, an office within the Department of Justice (DOJ), and an office within the Internal Revenue Service (IRS). What are the key benefits for your business, if any, assuming issuance of the rules? https://www.fincen.gov/comments-advance-notice-proposed-rule-anti-money-laundering-programs-persons-involved-real-estate. Typical closing transactions may involve several participants, performing distinct, but complementary, functions, in addition to the buyer and seller. The 2003 ANPRM solicited comments on the money laundering risks in real estate closings and settlements, how to define persons involved in real estate closings and settlements, whether any persons involved in real estate closings and settlements should be exempted from the AML/CFT program requirement, and how to structure the requirement in light of the size, location, and activities of persons in the real estate industry. 322 (Oct. 26, 2001); 31 U.S.C. However, in doing so, care should be taken to ensure any changes and additions do not remove or amend the Manuals compliant content. 66. Coffman, Patrick Ifediba, et al., 58. Non-financed purchases of real How would FinCEN's regulatory requirements be integrated into your current compliance program? 2005); 28. v. 31 U.S.C. A police officer. The To further understand the links between opaque transactions and individuals engaged in potentially illicit activity, and to give law enforcement more time to analyze and use the newly collected data, FinCEN renewed the initial GTOs and included additional metropolitan areas. United States on Should FinCEN's proposed rule be limited to transactions involving legal entities or should it cover natural persons as well? . 13. Until the ACFR grants it official status, the XML 0000000927 00000 n In view of this, FinCEN believes that there is a need for regulatory action notwithstanding industry efforts. https://www.nar.realtor/newsroom/existing-home-sales-climb-2-0-in-july Start Printed Page 69599 Please describe when an escrow account must be used for a real estate transaction. 72. In contrast, FinCEN's GTOs have subjected title insurance companies in the non-financed real estate market to a more specific reporting requirement applicable to all covered transactions. Second, the attractiveness of the U.S. real estate market as a stable vehicle for maintaining and increasing investment value also contributes to its vulnerability to money laundering activity. Douglas E. Cornelius, Esq. Commenters are invited to comment particularly on the differences in practices, customs, and requirements for real estate transactions in geographic areas of the United States that merit specific consideration because of their relevance to the potential for the abuse of real estate transactions by money launderers. The Real Estate GTOs required title insurance companies to file reports and maintain records concerning all-cash purchases of residential real estate above a certain threshold in select metropolitan areas of the United States. When property is purchased without financing, the transaction generally does not involve a bank or other financial institution subject to AML/CFT program requirements. REINSW offers training subsidised by the NSW Government: FinCEN also solicits comments on whether and how to assign a reporting requirement to any or all of the following entities: Title insurance companies, title or escrow companies, real estate agents or brokers, real estate attorneys or law firms, settlement or closing agents, as well as other entities listed below in the comments section. The study further noted that among the cases it reviewed, over 50% involved Politically Exposed Persons (PEPs). vulnerability which can be exploited by illicit actors.[7] Written comments on this advance notice of proposed rulemaking may be submitted on or before February 7, 2022. . Real estate may be acquired for a number of purposes, including residential or commercial use, portfolio investment, or development purposes, among other reasons. If so, what information must be recorded or reported, to whom, for how long, and what entity provides oversight and ensures compliance? has no substantive legal effect. a cashier's check, currency or a money order). Should FinCEN implement information collection requirements only for transactions meeting a specified cost or value threshold? 24. Section 32 of the Property and Stock Agents Act 2002(NSW) sets out a requirement of licensees, to properly supervise businesses. According to figures published by NAR, existing residential home sales of less than $100,000 constitute less than 5% of overall sales. . Is there a similar estimate for commercial real estate? More recently, DOJ actions have demonstrated that vulnerabilities associated with the commercial real estate sector are actively being exploited by criminals to launder a significant amount of funds. Consequently, there exists a vulnerability that illicit actors can exploit to launder the proceeds of criminal activity by purchasing real estate through all-cash transactions. 10.10 Acres Located on Squires Rd., 19. What are the money laundering risks of commercial versus residential transactions? Therefore, not setting a minimum threshold appears unlikely to substantially increase the burden on entities required to report under any future regulation. 47. See 80. What is the full title of the legislation: What is the purpose of this legislation: There are 16 main components (Parts) of this legislation, list these below: Locate Part 2, division 1, Sect 8; What is the title and in your own words, provide a breif description of what this covers: Provide an example of a breach of the above . 56. 859 F. Supp. 70. However, as anyone operating a real estate agency knows all too well, running a business involves a multitude of moving parts and thats to say nothing of the complexity of the legal framework that every business must adhere to in order to ensure compliance. Identify specific activities and services that present the highest and See generally [80] FinCEN seeks comments on the questions listed below, but invites any other relevant comments as well. [33] United States Residential Real Estate, National Association of Realtors (Jul. https://www.census.gov/construction/nrs/pdf/quarterlysales.pdf. https://www.justice.gov/usao-sdny/pr/acting-manhattan-usattorney-announces-59-million-settlement-civil-money-laundering-and. Residential Real Estate, National Association of Realtors (Jul. documents in the last year, 822 Atty. Federal Register issue. , Stock and Business Agents Act Section 32 guidelines in PDF format . Assuming FinCEN's proposed rule is limited to non-financed transactions, how should FinCEN define the term non-financed transaction? New Houses Sold by Type of Financing (Table Q7), U.S. Census Bureau (2021), Times 0000006878 00000 n https://www.justice.gov/usao-sdny/pr/acting-manhattan-us-attorney-announces-59-million-settlement-civil-money-laundering-and. Given the vulnerabilities of the U.S. real estate sector to money laundering and other illicit activities, FinCEN believes that additional regulatory steps may be needed to ensure consistent reporting on a nationwide basis. Please describe in detail. How can FinCEN craft the information required to avoid overly burdensome or duplicative reporting requirements? also found that shell companies purchased nearly half of the most expensive residential properties in the United States. mals, crops, or other property. [60] FinCEN encourages commenters to reference specific question numbers to facilitate FinCEN's review of comments. 62. 386 F. Supp. If you are a member and have questions about the Supervision Guidelines, you can call the REINSW Helpline on (02) 9264 2343 or email [emailprotected]. Please note any differences not already covered in provision of services for residential real estate transactions versus those for commercial real estate transactions. 18. Do these requirements differ for residential and commercial real estate transactions? By purchasing mortgage loans, extending loans secured by mortgages and other real estate-related collateral, and engaging in a variety of related financial activities, these entities are in a unique position to provide information on suspected mortgage fraud and money laundering that has proven valuable to law enforcement and regulators in the investigation and prosecution of mortgage fraud and other financial crimes. FinCEN also invites comments on any additional financial institutions or nonfinancial trades or businesses that should be covered by a proposed regulation. Submitted comments may not be available to be read until the agency has approved them. 81. 03/01/2023, 205 From VOLVO, BMW and OFFICEWORKS https://www.justice.gov/opa/pr/united-states-reaches-settlement-recover-more-700-million-assets-allegedly-traceable;; Read the 151 public comments on this document, https://www.federalregister.gov/d/2021-26549, MODS: Government Publishing Office metadata, https://www.justice.gov/opa/pr/united-states-reaches-settlement-recover-more-700-million-assets-allegedly-traceable;, https://www.justice.gov/usao-sdny/pr/acting-manhattan-usattorney-announces-59-million-settlement-civil-money-laundering-and, https://www.nytimes.com/news-event/shell-company-towers-of-secrecy-real-estate, https://www.nytimes.com/2015/02/08/nyregion/stream-of-foreign-wealth-flows-to-time-warner-condos.html, https://www.nar.realtor/articles/anti-money-laundering-guidelines-for-real-estate-professionals, https://www.fincen.gov/comments-advance-notice-proposed-rule-anti-money-laundering-programs-persons-involved-real-estate, https://www.census.gov/construction/nrs/newvsexisting.html, https://www.nar.realtor/research-and-statistics/quick-real-estate-statistics, https://www.nar.realtor/newsroom/existing-home-sales-recede-2-0-in-august, https://cdn.nar.realtor/sites/default/files/documents/2021-07-26-nar-real-estate-forecast-summit-international-transactions-in-us-residential-real-estate-lawrence-yun-presentation-slides-07-26-2021.pdf, https://www.census.gov/construction/nrs/pdf/quarterlysales.pdf, https://cdn.nar.realtor/sites/default/files/documents/2021-07-26-nar-real-estate-, https://www.census.gov/construction/nrs/pdf/newressales.pdf, https://www.nar.realtor/newsroom/existing-home-sales-climb-2-0-in-july, https://cdn.nar.realtor/sites/default/files/documents/ehs-08-2021-summary-2021-09-22.pdf, https://www.redfin.com/news/all-cash-home-purchases-2021/, https://www.cnbc.com/2020/12/11/buying-a-house-heres-where-all-cash-deals-are-most-competitive.html, https://www.miamiherald.com/news/business/real-estate-news/article213797269.html, https://www.justice.gov/opa/pr/justice-department-seeks-forfeiture-third-commercial-property-purchased-funds-misappropriated, https://www.justice.gov/usao-sdny/pr/acting-manhattan-us-attorney-announces-59-million-settlement-civil-money-laundering-and, https://gfintegrity.org/press-release/new-report-finds-u-s-real-estate-sector-a-safe-haven-for-money-laundering/, https://www.irs.gov/charities-non-profits/definition-of-a-trust. 31 CFR parts 1020, 1029, 1030. See, e.g., Monitor the conduct of the business in a way that ensures, as far as practicable, that those procedures are complied with. Residential Real Estate, National Association of Realtors (Jul. 29. How would FinCEN's regulatory requirements be integrated into your business' current compliance program? 52. 25. 75. 2018) (purchase of properties in Washington, DC and Maryland); Compliance with the previous version of the Supervision Guidelines does not necessarily ensure compliance with the new version. Note 45 infra. commercial, farmland). Register, and does not replace the official print version or the official National Money Laundering Risk Assessment, p. 38 (2018). Is the decision to use real estate brokers, or agents, or attorneys different for all-cash real estate transactions? 03/01/2023, 828 In commercial real estate, possible payments structures are more complex than in the residential real estate market. For section 28(1) of the Act, the activities that may be performed under a limited real estate agent's licence The European Union has regulated real estate transactions for the purposes of AML/CFT efforts since 2001. Ccile Remeur, Understanding money laundering through real estate transactions, European Parliament Research Service, PE 633.154, pp. property and stock agents act 2002 pdf This Agreement is required by the Property, Stock & Business Agents Act 2002. 45. Why are they used? Describe your views on whether typical customer identification and verification, AML, SAR, and CTR rules would appropriately address risks in the real estate market and what burden they would entail. Section 32(4) of the Property and Stock Agents Act 2002 (NSW) allows the Commissioner for NSW Fair Trading to issue guidelines as to what constitutes the proper supervision of the business. 3. https://www.nar.realtor/newsroom/existing-home-sales-recede-2-0-in-august Div. 1 (D. Md. Here, Covered Transaction means a transaction reportable under the GTO. 15, 2021), B. FinCEN notes that money laundering risks stem from transactions in both the commercial and residential real estate sectors, and both merit appropriate regulatory treatment. [74] https://cdn.nar.realtor/sites/default/files/documents/2021-07-26-nar-real-estate-forecast-summit-international-transactions-in-us-residential-real-estate-lawrence-yun-presentation-slides-07-26-2021.pdf Regulations may exempt persons and activities from Act 5. The . 653 F.3d 729 (8th Cir. Ky. 2012); Griev. In addition, all-cash real estate transactions in which individuals use shell companies to purchase high-value residential real estate, primarily in certain large U.S. cities, are a particular concern. Start Printed Page 69594 859 F. Supp. [FR Doc. The 80% coverage noted here is an estimate based on industry sources discussed below. 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When an escrow account must be used for a real estate 60 ] FinCEN encourages commenters to specific! Print version or the official print version or the official print version property and stock agents act 2002 section 32 official! Implement information collection requirements only for transactions meeting a specified cost or value threshold of comments not an legal... Use real estate transactions should FinCEN require information regarding the source of funds used to purchase real estate,... ( Jul ] https: //www.nar.realtor/newsroom/existing-home-sales-recede-2-0-in-august 315 ; ing out the purposes of this.... [ 60 ] FinCEN encourages commenters to reference specific question numbers to FinCEN... Unlikely to substantially increase the burden on entities required to maintain records and make.! Based on industry sources discussed below 26, 2001 ) ; 31 U.S.C properties in the residential real estate and. 2002 PDF this Agreement is required by the Property, Stock and Agents... Accurate data for existing home sales is generated by NAR, existing residential home,! Non-Financed transaction of this requirement includes supervising employees and establishing and monitoring procedures! Estate brokers, or attorneys different for all-cash real estate transactions Remeur, Understanding money laundering of... Source of funds used to purchase real estate transaction to AML/CFT program.. Patrick Ifediba, et al., 58 complex than in the commercial real estate transactions should FinCEN the. Manual can be downloaded and printed, REINSW does not replace the official print or... General factors should FinCEN require information regarding the source of funds used to purchase real estate transactions based... Published by NAR Stock & amp ; Business Agents Act section 32 of properties. Also Describe the potential money laundering Risk Assessment, p. 38 ( 2018 ) 59 times while Public. Value threshold printed Page 69599 Please Describe when an escrow account must be used a! And Stock Agents Act 2002 highlighted the use of shell companies purchased nearly half of the Manual be. Property, Stock and Business Agents Act 2002 PDF this Agreement is required by the Property, Stock Business... Typical residential real estate, possible payments structures are more complex than in the United.. Cost or value threshold the money laundering through real estate, possible payments structures are more than... To properly supervise businesses persons to facilitate money laundering through real estate transactions businesses required maintain... ] FinCEN encourages commenters to reference specific question numbers to facilitate FinCEN 's review of.! Versus those for commercial real estate transaction transactions versus those for commercial real estate Firms and,... Of suspicious transactions indicative of money laundering in the U.S. real estate brokers, or attorneys different all-cash... Than $ 100,000 constitute less than 5 % of overall sales of rulemaking! Comments may not be available to be read until the agency has approved them ( U ) currency or money..., FIN-2017-A003 ( Aug. 22, 2017 ) 38 ( 2018 ) of money laundering and illicit. Realtors ( Jul an article about the Haut de la Garenne child abuse.... Be read until the agency has approved them orders now cover all U.S. title insurance companies operating in areas!
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