Bulletin: TX2022005

Dear Associates:

This bulletin is continuing guidance on the FinCEN Geographic Targeting Orders (GTO) which were issued to all underwriters. A New GTO has been issued further expanding the geographic regions subject to reporting requirements and extends the effective date of the reporting requirements of the existing geographic regions. As a reminder, the GTO has defined a covered business to include Stewart Title Insurance Company, Stewart Title Guaranty Company (the Stewart family), its employees and its authorized Title Agents. The amended GTO has defined a covered transaction as any transaction that will close involving purchases of properties within the Texas counties of Harris, Montgomery, or Webb, effective beginning November 25, 2022, and ending on April 24, 2023 (except as otherwise provided in Section III.C of the Geographic Targeting Order). The terms of this Order for purchases in all other counties covered by this Order are effective beginning October 27, 2022, and ending on April 24, 2023, involving:

1. Residential real property located in the Counties of The Texas counties of Bexar, Tarrant, Dallas, with the addition of Harris, Montgomery, and Webb counties, effective beginning November 25, 2022;

2. The proposed insured/buyer is a Legal Entity, defined as a corporation, limited liability company, partnership or other similar business entity whether formed under the laws of a state, or the United States, or a foreign jurisdiction, OTHER THAN a business whose common stock or analogous equity interests are listed on a securities exchange regulated by the Securities Exchange Commission (“SEC”) or a self-regulatory organization registered with the SEC, or an entity solely owned by such a business and

3. The purchase price of the residential real property is in the amount of $300,000 or more and

4. Such purchase is made without a bank loan or other similar form of external financing (Financing from a private lender, seller or other business is considered a reportable transaction.), and

5. Such purchase is made, at least in part, using currency or a cashier's check, a certified check, a traveler's check, a personal check, a business check, a money order in any form, a funds transfer, or virtual currency. (An attorney trust or escrow check is considered a business check for reporting purposes). There is no de minimus amount below which the reporting is not triggered.

In the event a transaction meets the above criteria, (remember, the transaction must meet the current prong test (covered location, improved residential property, over $300,000.00, without institutional financing and in cash or an above-mentioned cash equivalent)) then the covered transaction shall be reported to FinCEN by filing the Currency Transaction Report ("CTR") within thirty (30) days of the closing. Please see Stewart Bulletin SLS2022009 for the requirements.

In Texas, the “EXCEPTION/REQUIREMENT” outlined in SLS Bulletin 2022009 should be listed as a requirement on Schedule C of the commitment.

If you are in need of assistance or have questions regarding the order, please reach out to your manager, agency representative, Stewart's Legal Department or by email to FINCENreports@stewart.com.

If you have any questions relating to this or other bulletins, please contact a Stewart Title Guaranty Company underwriter.

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