If the purchase of a one to four family property by a corporation, LLC or partnership (entity) was to be accomplished by paying all cash, it was always a business decision and a private matter. Since March 1, 2016, however, significant disclosure1 requirements regarding the identity of the members of the buyer vehicle (beneficial owners) and the source of the acquisition funds prevail for the cash purchase of high-end residential properties in select counties in New York, California, Florida and Texas.
While the identity of sundry principals was once effectively shielded behind the purchasing entity, it must now be disclosed. While none of the information reported is intended for public dissemination—it is solely for analysis by the Financial Crimes Enforcement Network (FinCEN) and corresponding agencies—should a violation appear, there is no assurance that their identity will remain confined to FinCEN or a related agency.
