Policy Issues

Real Estate Coalition Comments on Beneficial Ownership Information Reporting Requirements

February 4, 2022

LETTER

A coalition of five real estate organizations, including The Real Estate Roundtable, on Feb. 4, 2022 submitted comments to the U.S. Department of the Treasury (Treasury) and the Financial Crimes Enforcement Network (FinCEN) that included the following:

"While the real estate industry supports the goal of preventing money laundering, terrorism financing or other crimes, we believe there are aspects of the proposed rule that are flawed and should be reconsidered per our recommendations.

First, the rule and certain definitions require greater clarity in order for businesses to accurately comply with the rule. Second, the shortened deadlines for submission of information do not comply with the intent of the CTA. Third, the proposed rule unnecessarily requests information outside of the scope and intent of the CTA.

We also remind FinCEN that the CTA directs Treasury to seek to minimize burdens on reporting companies associated with the collection of beneficial ownership information. We appreciate the opportunity to provide our comments and voice our concerns regarding the implementation of the CTA. We stand ready to work directly with FinCEN to develop a clear, transparent, and secure set of rules for our industry."

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