[Legislativecommittee1] ALTA Call on FinCEN proposed rules - March 7; need volunteers to work on WLTA response

[Maureen Pfaff]

Sean,

I registered for the call as well.  I will work on some comments that I can submit personally or which can be used in the WLTA response.

Thanks,
Maureen
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From: Legislativecommittee1 <legislativecommittee1-bounces at washingtonlandtitle.com> on behalf of Holland, Sean <Sean.Holland at fnf.com>
Sent: Wednesday, February 28, 2024 9:15 AM
To: 1 WLTA Legislative Committee <legislativecommittee1 at washingtonlandtitle.com>
Subject: [Legislativecommittee1] ALTA Call on FinCEN proposed rules - March 7; need volunteers to work on WLTA response

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Yesterday’s SLRAC call covered FinCEN’s proposed rules (attached).  The reporting requirements currently applying in 69 counties subject to Geographic Targeting Orders would be imposed on transactions nation-wide.   FinCEN recognizes that the proposed rules would impose staggering burdens on title companies.  This is what FinCEN says on page 90 about the potential economic impact of the rules:



FinCEN aggregate cost estimates suggest that first year costs will be between

approximately $267.3 million and $476.2 million and that the current dollar value of the

aggregate costs in subsequent years will be between approximately $245.0 million and $453.9

million annually. FinCEN also invites public comment on these estimates.



Any comments on the proposed rules must be submitted by April 16.



JP and I are both planning on being on the March 7 call “ALTA Insights: Learn How Proposed Real Estate Money Laundering Rule Impacts You.”  If you are interested, you can register for the call (it’s free) at  https://portal.alta.org/events/event-details/?id=b3ae2f48-20d0-ee11-92bc-6045bdba0692



We could use at least a couple of volunteers to participate in preparing comments for the WLTA to submit.   In particular, I hope some agent members will consider submitting their own comments outlining the burden these proposed rules would impose on their businesses.



Sean Holland

VP | Underwriting Counsel

Washington & Montana

Fidelity National Title Group

701 Fifth Avenue, Suite 2700

Seattle, Washington 98104

Mobile:  206-308-6823

Sean.Holland at fnf.com<mailto:Sean.Holland at fnf.com>





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