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

[Megan Powell]

I registered to attend and would be happy to participating in the drafting of the comments.  Here is another webinar that might be of interest:  Corporate Transparency Act: A Discussion with FinCEN (on24.com)<https://event.on24.com/wcc/r/4505507/30D77BB08E1A89B22B7370A72FEC156B?partnerref=Pardot>
__________________________________________________
Megan Powell
Director of Underwriting - Direct Division

[Description: https://www.firstam.com/assets/email/images/fa-logo-signature.jpg]
First American Title Insurance Company
Madison Centre
920 Fifth Avenue, Suite 1250
Seattle, WA 98104

Direct: 206-615-3285
Mobile: 206-375-3491
Email: mpowell at firstam.com<mailto:mpowell at firstam.com>

A member of the First American Financial Corporation<http://www.firstam.com/>
family of companies  | NYSE: FAF<http://www.firstam.com/investor>



From: Legislativecommittee1 <legislativecommittee1-bounces at washingtonlandtitle.com> On Behalf Of Maureen Pfaff
Sent: Wednesday, February 28, 2024 3:35 PM
To: Holland, Sean <Sean.Holland at fnf.com>; 1 WLTA Legislative Committee <legislativecommittee1 at washingtonlandtitle.com>
Subject: [External] Re: [Legislativecommittee1] ALTA Call on FinCEN proposed rules - March 7; need volunteers to work on WLTA response

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
________________________________
From: Legislativecommittee1 <legislativecommittee1-bounces at washingtonlandtitle.com<mailto:legislativecommittee1-bounces at washingtonlandtitle.com>> on behalf of Holland, Sean <Sean.Holland at fnf.com<mailto:Sean.Holland at fnf.com>>
Sent: Wednesday, February 28, 2024 9:15 AM
To: 1 WLTA Legislative Committee <legislativecommittee1 at washingtonlandtitle.com<mailto: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<https://urldefense.com/v3/__https:/portal.alta.org/events/event-details/?id=b3ae2f48-20d0-ee11-92bc-6045bdba0692__;!!L1aKtqoz4WY!f9VUYyzlgh5lRIiygzIMC41IOi-1lzxVoLbu-Q6FYf9QDPK2nIg6-1NMnZM0dk13UyrD3qO-B8kCFlw8OHs2$>



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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