A new Geographic Targeting Order (GTO) has been issued effective November 17, 2018 and ending on May 15, 2019.
Good News #1: the confidentiality provision has been eliminated. You may share the GTO with your clients and customers and discuss its requirements as need be. However, structuring a transaction to avoid the reporting requirement is still forbidden.
Good News #2: a purchase by a trust of any kind is no longer reportable.
Good News #3: the geographic territories in Florida have not changed (i.e. covered transactions in Miami-Dade, Broward or Palm Beach counties).
Bad News: the threshold for reporting remains at $300,000.
View the New Geographic Targeting Order (GTO)
Criteria for reporting under new GTO:
- The transaction involves a purchase of one or more residential real properties (not vacant land) in Miami-Dade, Broward, or Palm Beach Counties; and
- The total purchase price is $300,000.00 or more; and
- The purchaser is a corporation, limited liability company (LLC), partnership, or other similar legal entity. (The definition does not include trusts or natural persons); and
- The purchaser purchases the residential real property without a bank loan or other similar form of institutional financing; and
- The purchaser pays any part of the purchase price using currency, cashier’s checks, certified checks, traveler’s checks, money orders, business or personal checks or wire fund transfers or payments (no requirement to report check numbers or wire routing numbers).