FinCEN AML Decision Assessment

1
Does this transaction involve the transfer of “residential real property”?* This field is required.Which means real property with a 1-4 family structure or condo, vacant land zoned or where buyer intends to build such structures (including builder projects), co-ops, and all other property that include or intend to include 1-4 family use (e.g., mixed-use like apartments over strip mall or 5+ structure with intent for 1-4 family residential use)
YESNO
2
Is this transfer any one of the following?* This field is required.Is this transfer one of the following? - A grant, transfer, or revocation of an easement; - Resulting from the death of an individual, whether pursuant to the terms of a decedent’s will or the terms of a trust, the operation of law, or by contractual provision; - Incident to divorce or dissolution of a marriage or civil union; - To a bankruptcy estate; or - Supervised by a court in the U.S.; - For no consideration made by an individual, either alone or with the individual’s spouse, to a trust of which that individual, that individual’s spouse, or both of them, are the settlors) or grantor(s) - Trust Exclusion; or - To a qualified intermediary (but only TO the qualified intermediary)
YESNO
3
Is the transferee (buyer) an entity or trust?* This field is required.Transferee Entity means a corporation, limited liability company, partnership or other similar business - domestic or foreign - other than a publicly traded or self-regulated entity whose interests are regulated by the Securities Exchange Commission. Transferee Trust is a legal arrangement created when a person places assets under control of a trustee for benefit of a beneficiary or a specified purpose - domestic or foreign but not a securities-related or statutory trust.
YESNO
4
Is the transfer “Non-Financed”?* This field is required. Meaning the lender funds are not from a lender (or owned by a lender) that is subject to Bank Secrecy Act rules or required to file Suspicious Activity Reports, like state or federal credit unions, chartered banks and the well-recognized, large, national financial lenders. “Non-financed” transfers include all cash deals, all other lenders, private lenders, and seller carryback and investor loans.
YESNO
5
The information provided here is for general informational purposes only.* This field is required.For additional FinCEN AML rule guidance and information for a specific transaction, contact ClosePoint USA.
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