New LLC Disclosure laws - Treasury Dept Expands Pilot Program

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Anyone familiar with the details of this new disclosure law? †I've read that it only applies to residential properties, which seems odd given the amount of money being poured into commercial real estate in major cities by international buyers.

http://therealdeal.com/la/2016/07/29/la-real-estate-industry-says-new-llc-disclosure-rules-will-have-little-impact-on-market/


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And only in certain markets. Haven't had enough time or inclination to look into this further.

Edit: Thank you for this thread. †I just realized that I have a very important reason to read the Treas. Regs. on this.

The Treasury Departmentís latest expansion of a pilot program requires title companies to identify the true buyers behind anonymous, all-cash deals in L.A. The rules will apply to all residential properties priced at more than $2 million in Los Angeles County as well as San Diego County. The program, which has already been in effect since March in New York City and Miami, will go into effect in L.A. starting August 28.
99% of people aren't affected

Relies on title insurance company to report to Treasury (FinCEN). †Don't want disclosure? †Don't buy title insurance. †Problem solved.
Expansion of pilot (July 2016): †https://www.fincen.gov/news_room/nr/html/20160727.html
Original pilot (Jan 2016): †https://www.fincen.gov/news_room/nr/html/20160113.html
FAQs: †https://www.fincen.gov/news_room/nr/pdf/FAQsRealEstateGTO.pdf

like this country has the money to do this,,,guess just add it on to the 20 trillion..

rufflesinc said:   
The Treasury Departmentís latest expansion of a pilot program requires title companies to identify the true buyers behind anonymous, all-cash deals in L.A. The rules will apply to all residential properties priced at more than $2 million in Los Angeles County as well as San Diego County. The program, which has already been in effect since March in New York City and Miami, will go into effect in L.A. starting August 28.
99% of people aren't affected

† Give them a few years lol

Crazytree said:   
rufflesinc said:   
The Treasury Departmentís latest expansion of a pilot program requires title companies to identify the true buyers behind anonymous, all-cash deals in L.A. The rules will apply to all residential properties priced at more than $2 million in Los Angeles County as well as San Diego County. The program, which has already been in effect since March in New York City and Miami, will go into effect in L.A. starting August 28.
99% of people aren't affected

† Give them a few years lol

† most people don't do it anonymously and certainly not all cash. So it will be inapplicable to most people even if they expand it since the Treasury will have access to the public records already

rufflesinc said:   
† most people don't do it anonymously and certainly not all cash. So it will be inapplicable to most people even if they expand it since the Treasury will have access to the public records already

††
1. There are certainly many legitimate reasons to buy a house using a trust, where the buyer would like privacy regarding beneficiaries and other details.
2. Assuming other criteria are met, even paying a PORTION of the purchase price with a CASHIER'S CHECK triggers reporting. No actual currency needed. †Section II.A.2.v of the rules.

P.S. You may want to read the rules before making blanket statements.

tuphat said:   rufflesinc said:   
† most people don't do it anonymously and certainly not all cash. So it will be inapplicable to most people even if they expand it since the Treasury will have access to the public records already

††
1. There are certainly many legitimate reasons to buy a house using a trust, where the buyer would like privacy regarding beneficiaries and other details.
2. Assuming other criteria are met, even paying a PORTION of the purchase price with a CASHIER'S CHECK triggers reporting. No actual currency needed. †Section II.A.2.v of the rules.

P.S. You may want to read the rules before making blanket statements.

And what percent of purchases are made with a trust?
i search the property records all the time and there are more llc than trust.

rufflesinc said:   
tuphat said:   
rufflesinc said:   
† most people don't do it anonymously and certainly not all cash. So it will be inapplicable to most people even if they expand it since the Treasury will have access to the public records already

††
1. There are certainly many legitimate reasons to buy a house using a trust, where the buyer would like privacy regarding beneficiaries and other details.
2. Assuming other criteria are met, even paying a PORTION of the purchase price with a CASHIER'S CHECK triggers reporting. No actual currency needed. †Section II.A.2.v of the rules.

P.S. You may want to read the rules before making blanket statements.

And what percent of purchases are made with a trust?
i search the property records all the time and there are more llc than trust.

† There's also many legitimate reasons to use an LLC or partnership, as well. †Very common in second home areas, where several families may jointly own a home. †Also used to hold rental properties. †I don't have percentages for you, just suggesting that there are entirely legitimate reasons for using all of these entities. †And legitimate reasons for the privacy that they afford.

tuphat said:   
rufflesinc said:   
tuphat said:   
rufflesinc said:   
† most people don't do it anonymously and certainly not all cash. So it will be inapplicable to most people even if they expand it since the Treasury will have access to the public records already

††
1. There are certainly many legitimate reasons to buy a house using a trust, where the buyer would like privacy regarding beneficiaries and other details.
2. Assuming other criteria are met, even paying a PORTION of the purchase price with a CASHIER'S CHECK triggers reporting. No actual currency needed. †Section II.A.2.v of the rules.

P.S. You may want to read the rules before making blanket statements.

And what percent of purchases are made with a trust?
i search the property records all the time and there are more llc than trust.

† There's also many legitimate reasons to use an LLC or partnership, as well. †Very common in second home areas, where several families may jointly own a home. †Also used to hold rental properties. †I don't have percentages for you, just suggesting that there are entirely legitimate reasons for using all of these entities. †And legitimate reasons for the privacy that they afford.

† That doesn't change the fact that 99% of people won't be affected

This is really targeting people (particularly international) buying properties for money laundering purposes. If you take $10 million and try to deposit it at Goldman Sachs, they run full KYC (Know Your Customer) background on you. If you take that $10 million and buy a NYC condo with it, you can do it completely anonymously.

I was discussing several of these new ultra-high-end buildings ($5 million per unit and up) that have gone up in Midtown with a friend who's a real estate broker in NYC. He noted that he's "sold a lot of apartments WITH washing machines before, but these buildings ARE washing machines."



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