Comment from Fast
Beau FastOpposeIndividual
Summary: A title and settlement industry professional opposes the rule, stating that it creates unnecessary delays, costs, and privacy concerns for buyers and sellers. The commenter argues that the rule is overreaching in scope, particularly regarding low-dollar transactions and transfers that show no signs of unusual activity.
The rule created delays and added costs to closing applicable transactions. Many buyer and sellers objected to providing their personal information along with costs (pass through) related to filing with FinCEN. Most exemptions to filing do not apply when reviewing the rule and FAQs. The rule itself feels overreaching in its scope and that was the opinion of the majority of buyers/sellers who were forced to comply. Many complaints over low dollar transactions qualifying and transfers without consideration. The rule is so broad that it drew comments such as "overreaching government surveillance," "unlawful search without probably cause," etc. As a title/settlement industry professional, I would keep my opinions to myself and encourage a calm approach, but it is hard to argue with so many transactions not showing any signs of unusual activity being reported.