We break down the FinCEN reporting cascade and explain who is responsible for filing the new FinCEN report. We walk through the seven options in the cascade, focusing on the first few, which typically point to the title company. We discuss how the closing or settlement agent, the person who prepared the closing statement, or whoever recorded the deed with the county recorder’s office may be responsible for filing. In Utah, this responsibility usually falls to the title and escrow company. | Mr.

Beneficial ownership transparency for development finance