FinCEN, GTOs, and BOI: What Real Estate Investors in Colorado Need to Know
As Colorado’s real estate market continues to attract investors, particularly in the Denver metro area, federal compliance requirements have become an essential part of the closing process—especially for all-cash and entity-based transactions. At Elevated Title, we specialize in working with real estate investors, and we take the lead in managing all FinCEN reporting requirements on your behalf. Understanding how these regulations work—and what’s required from you—helps ensure smooth, timely closings.
A Geographic Targeting Order (GTO) is a federal mandate issued by the Financial Crimes Enforcement Network (FinCEN) to help detect and deter money laundering in real estate. The GTO requires title companies, like Elevated Title, to report specific details about certain high-value, all-cash residential transactions made by legal entities. In the Denver metro area, any residential transaction of $300,000 or more qualifies if the buyer is an entity such as an LLC, corporation, partnership, or trust, and the purchase is made without a traditional mortgage. This includes transactions funded by private money lenders or hard money loans. If there is no institutional mortgage recorded, FinCEN treats it as an “all-cash” deal, and the reporting requirement applies.
When a transaction falls within GTO parameters, Elevated Title takes full responsibility for submitting the required report to FinCEN. We identify and verify the beneficial owners of the purchasing entity—defined as anyone who owns or controls 25% or more—and collect a government-issued photo ID for each of them. Our team then securely submits the necessary FinCEN Form 8300 on your behalf. All we ask from our clients is timely cooperation in providing the required documentation to keep closings on track.
In addition to GTOs, recent legislation known as the Corporate Transparency Act (CTA) introduces a separate but related requirement. Under the CTA, most legal entities are now required to file Beneficial Ownership Information (BOI) directly with FinCEN. Unlike the GTO, this is not handled by the title company. The obligation to file rests with the entity itself. Entities created before 2024 must file their BOI reports by January 1, 2025. Those formed during 2024 have 90 days to file, and beginning in 2025, new entities will have just 30 days. These reports contain information similar to what is required under the GTO—names, birthdates, addresses, and identifying documents for all beneficial owners.
To simplify BOI compliance, individuals can request a FinCEN ID after submitting their ownership information. A FinCEN ID is a unique number that represents their filed information. If you’ve obtained a FinCEN ID, you can provide it to Elevated Title during a GTO-covered transaction, allowing us to use it in place of resubmitting your personal data. This can be particularly helpful for investors involved in multiple deals or entities, providing a streamlined and secure way to meet reporting requirements.
Compliance with FinCEN’s GTO and BOI requirements has become a routine part of entity-based transactions in Colorado. While the rules are complex, they don’t have to disrupt your deal. At Elevated Title, we manage GTO reporting from start to finish and are happy to guide our clients through what’s needed for a successful, compliant closing. Whether you’re using private funds or buying through an LLC, we’re here to make sure nothing slows you down.
Elevated Title — A Step Above the Rest
Have questions about your next transaction? Contact our expert team today to learn how we support investors with efficient closings and full compliance across Colorado.