 through the real estate sector in the United States. I'd like to first thank our co-sponsors for this event, Global Financial Integrity Action Center on Racing the Economy, Transparency International US Office and the California Reinvestment Coalition. The Financial Accountability and Corporate Transparency Coalition FACT is a nonpartisan alliance of over 100 state national and international organizations promoting a fair global tax system and combating the harmful impacts of corrupt financial practices. Recently, we've been heartened to see that the Biden administration has declared the global fight against corruption to be a national security priority. Too often though, the fight against global corruption and illicit financial flows is seen only as a national security or good governance agenda. Unconnected to domestic policy agendas and the struggles of working Americans. That's why we are so happy to have a panel today that helps us bridge this divide. Money laundering in the US real estate sector and its impact on the US housing market is one concrete example of how these issues intersect with domestic priorities, including addressing economic inequality. The Biden administration has proposed a quote unquote foreign policy for the middle class and Biden's national security advisor, Jake Sullivan has said, quote, everything we do in our foreign policy and national security will be measured by a basic metric. Is it going to make better safer and easier lives for working families? US housing inventory is low and housing prices are soaring. Real estate money laundering distorts housing prices and affects American families looking for affordable housing. An anti-corruption strategy that tackles corruption in the real estate sector would be a concrete manifestation of this policy aspiration. The good news is momentum for reform is strong. Recently, the G7 group of nations highlighted real estate money laundering as a major issue that needs to be addressed by these advanced economies. The US has elevated corruption as a core national security interest and the Biden administration has asked all departments and agencies to develop plans for combating corruption. And finally, President Biden has announced the seven for democracy at the end, at the end of this year in December, that will be a key moment for advancing key anti-corruption reforms. In terms of our topic today, our current approach to these problems is woefully inadequate and our real estate sector, both residential and commercial, is a haven for criminals and kleptocrats, as we'll hear in the presentation by Lakshmi Kumar and their groundbreaking acres of money laundering report. As of today, the US is the only G7 country that doesn't require the real estate sector to comply with anti-money laundering requirements. At the federal level, the Treasury Department can act to start a rulemaking process to create a national regime for collecting information on the true owners of real estate, the beneficial owners, particularly residential real estate. Improving transparency is an important first step to help solve the problems we'll hear about today. We'll hear more also about what can be done at the state and local level. As a reminder, this event is on the record and being recorded. And in terms of how we're organizing today's event, first we'll hear from Lakshmi Kumar, who is the policy director at Global Financial Integrity and a co-author of the Acres of Money Report. We'll then hear from Sophia Lopez, deputy campaign director at Acre, the Action Center on Race and the Economy. That she'll be followed by Joseph Abawa, who is the organizing and campaigns director at the California Reinvestment Coalition. And finally, we'll hear from Chuck Collins, director of the program on inequality and the common good at the Institute for Policy Studies. And most recently, the author of The Wealth Orders, how billionaires paid millions to hide trillions. We'll hear from Lakshmi for about 15 minutes and then the other panelists will have about five minutes each. We want to make sure that we have plenty of time for your questions. And so please get those questions ready and you can submit them using the chat or by raising your virtual hand. I'd now like to hand it over to Lakshmi. Thank you so much, Ian. If I move past my 15 minutes, please feel free to remind me and I will quickly wrap things up. I think a good place to start is to understand what current US policy is in this regard. And the current US policy that governs the real estate market to capture illicit financial flows are the geographic targeting orders. Now in a nutshell, these orders are temporary. They are location specific and they are triggered by purchases above a certain monetary threshold. When I say they are temporary and location specific, it simply means that these orders have to be renewed once every six months. Currently, because they started in 2016, they are applicable across 22 counties in the US and they have varying monetary thresholds. They started off between a million. They sort of slowly come down to 300,000 but when in all cash purchase using a company is made of a residential property, it triggers a reporting requirement essentially where a title agent has to report to FinCEN who is the individual that has purchased that property. Now it's important to understand here what the term residential real property means. Residential real property really means the purchase of a single family home or one to four units of a residential residence. So if you were to buy an entire condominium or an entire apartment building that becomes commercial real estate. That is no longer residential real estate. So this really is targeting individual purchases of homes. Now since it's been, sorry, let me sort of quickly move back a little which is that while this has been in effect since 2016, a lot of us within the advocacy community have for the variety of reasons have advocated that a new national regime be created which makes these requirements applicable nationwide and removes any dollar thresholds around the reporting requirements. Our approach in doing this particular report was to provide the evidence based to show that the current approach of geographic targeting orders is not sufficient nor is it entirely adequate by no means is it adequate to capture and address the scale and size of the problem in the US. And to do that, we looked at over a five-year period publicly reported information on real estate money laundering cases in the US to understand what trends were like, how money was coming into the country, what methods were doing and whether the geographic targeting order policy was sufficient and adequate to address all these multi-various schemes and methods and modalities we were seeing. And the short answer is absolutely not. And that is what I hope to go into in the next 12 minutes that I have left. So in a nutshell, this is what the main findings of our study work. Over a period of five years, we were able to identify 56 cases and this is from reputable news sources, the work that's been done by our panelists, Chuck Collins, yes, and some of that was incredibly useful information for us, forfeiture, ideology and other government proceedings which identified money, illicit money being funneled through the real estate sector. As you can see, over 56 cases, we were able to identify well over $2 billion that was housed in the real estate market. Now, if you want to break this down across the 56 cases and on a per case value average out, the values are staggering. Now, to go back to what I said at the beginning which is about the GTOs and why we did this report was to really understand whether it made sense because the rationale behind the GTOs is that if you are in criminal laundering money, you will want to move into luxury real estate markets because that's where you get your best bang for your buck. We found that 60% of all the cases we found occurred in non-GTO counties. To add sort of further complexity to this and some of this was because there have been a series of reports whether it's the Treasury, whether it is the government accountability office that have all recognized the risks that the real estate sector posed to US national security, US economy and none of them had really talked about a focus on how much of this money was coming from outside the US and how much of it involved politically exposed persons by which I mean, individuals that have a whole government office or have close associations to those in government office. And in both cases we found there was a staggering number which is over 50% of the cases. Again, as Ian and others have spoken about as we have tried to talk about because a lot of this is to lend an air of opacity to provide arms length distance from your ownership so you don't know who owns this. And that's part of the challenge in trying to find and track down abuse. And a lot of this is done through legal structures both legal entities formed and registered in the US but more importantly, legal entities formed and registered outside the US were also used to purchase property which adds to the challenge. The last finding that I will talk about is that we were able to see that while the GTOs as I mentioned focus entirely on residential real estate 30% of the cases involved commercial real estate. By this I mean anything that was above four residential units falls into commercial real estate. So whether it's a garage, whether it's an apartment building, whether it is a hotel, all of that becomes commercial real estate and with significantly higher values per case than residential real estate, yet it's an unpacked market. Now, this sort of breaks it down and shows you sort of what the split was like between residential, commercial, how much of this money was coming from outside the country. Also in a lot of the cases this money was coming into sanctions evasion. A lot of Iran and North Korea and money that was funneled into the US real estate market came as a consequence of professional money laundress evading sanctions. Now, as we talk about this because as we sort of sit together on this panel to really talk about where this is going you can see that even as we talk about commercial real estate for anything under 2.5 million US dollars the majority of it continues to be all cash purchases especially by foreign buyers in the US 58% of all commercial purchases in the US that is unregulated, no questions asked is all cash. And I think the big thing that we want to sort of underscore in terms of sort of long-term trajectory and asks is that is the need to really identify and disclose who individuals are? Whether we see this in residential or commercial there are real-world consequences to this. One, we've talked a lot about sort of importing corruption presenting national security risks but when you're talking about sort of commercial real estate that often uses private equity, other legal structures you have multiple owners and this chart that I have here shows you how the one MBB standard the complex system of legal entities and companies that were used to acquire a hotel. Now, this could be the same thing that happens when someone tries to acquire an apartment building or a condo and that's what we've seen happen in Cleveland with the, in the case of sort of the Kolmoisky brothers where it's cost real world it is devastated communities because it was just ramp and money laundering they didn't actually care to list the economy in the state. Now, if you break this down you can see that the current US policy only covers 25 or 50 states. So 64% of states are not subject to a GTO because GTOs only cover counties. Now, if you break this down further you can see that the majority of cases 39% of cases feature only GTO. A lot of the cases overlap with properties and that was 60% of the cases. Now, the last piece I wanna show is that as you see where GTOs are put in place because you can look at the green bubble and the white bubble here the green bubble shows the green within white shows you where GTOs are put in place when there were a certain number of cases. For the vast majority including Maricopa, Arizona there is no evidence of a GTO even though there's in the plethora of cases same thing we see with Ohio after there's a huge number of cases that have occurred that we haven't rarely seen. And you also see that in Texas which has a lot of very few counties covered but a significant number of real estate money laundering that goes through. So I think in short and I do wanna make sure that all our other excellent panelists have adequate time to sort of really talk about the impact support some of these negative consequences can be is that knowing the identity of the individuals that own and purchase property in the US is critical to safeguarding against the ill effects and especially for residential real estate it is important that a new national regime without any dollar threshold requiring beneficial owners to report when legal entities are used to purchase residential real estate. And I realize that's a mouthful but that's because we are really trying to target a very subset of behavior which is you use a company to hide your identity and buy your property and knowing who does that across the country helps law enforcement. Because this ties so deeply into beneficial ownership it is important that we continue to prioritize the and fast track the implementation of the registry. Finally, we do need a concrete system to address commercial real estate because there is nothing to talk about what the ill effects from there. I know everyone else from the panel will go into it further. And finally as we talk about investments in homes and hotels a lot of this investment does come through the EB-5 investor program as well. And our case examples show that there were Chinese politicians, professional money launderers from Iran or helping the Iranian and North Korean government all abuse this program. And therefore understanding those risks that is incredibly important. I will stop then happy to answer any questions or go into detail or anything else. Thank you so much. Thank you Lakshmi. That was a great overview of a complex issue. Just one quick question right now. As some of the people on the call may know the FACT Coalition fought for many years to get a new law in place the Corporate Transparency Act which is now being implemented by Treasury which would set up a database of beneficial ownership of information for corporate entities. Could you... The Transparency Act would help this problem but also what gaps would remain even if the Corporate Transparency Act is implemented? That is a fantastic question Ian. And you're absolutely right. The Corporate Transparency Act would go a significant way in addressing the problem because essentially if you used a company or an LLC to register in the US to register in the US and buy property it would ought that the person who is the beneficial owner of such an entity would have their name recorded with FinCEN. I think things become complex when you're looking at other types of legal vehicles whether it is a trust. What about a foreign registered legal vehicle? Because the way the CTA is worded it is the phrasing is to do business when it is formed or registered to do business. And the truth is depending in the US in which state you're purchasing property the purchase of a property especially residential property does not necessarily qualify as business. So there are circumstances especially when you're looking at foreign legal vehicles foreign registered legal entities like trusts or LLCs that are outside the US that may not fall within the purview of the CTA. And so one I think for all of us at least making sure that we find a way to get that in or at the very least making sure that that is not a safe haven or a place where every criminal says, ah that's my go-to option. And I think addressing that through a national regime for real estate purchases through any kind of legal vehicle is would be critical. Great, thanks so much. We'll now turn to Sophia Lopez who is the deputy campaign director for housing at the Action Center on Race in the Economy. Sophia, I know Acre is doing amazing work at the grassroots level on housing rights. Could you talk a bit about how opacity in the real estate sector is impacting the campaigning you and your partners are doing? Yes, absolutely. Thank you, Ian. And thank you so much, Lakshmi. I'm in awe of the research that you did. It's so beautifully presented. I think the report is really fabulous and very helpful. I think it's an angle of this work that honestly doesn't come up for me all that often but I think sparks a lot of thoughts about how concerns that grassroots organizations and organizations like mine have about the opacity of entities like private equity could also dovetail with exactly what it is that you're laying out. I'll say very quickly, the Action Center on Race in the Economy is we consider ourselves a campaign hub. So we support grassroots organizations that want to take on, I focus on housing justice but a range of issues all rooted in the ways in which Wall Street extracts from communities of color. And as Ian mentioned, I focus on housing and my particular focus is on the financialization of housing or the presence of Wall Street with them housing. So I think probably as most people on this phone call know, since the global financial crisis there's been this massive influx of institutional investors within housing and that includes pension funds, insurance, companies, hedge funds, private equity and the list goes on. And most people on this call have probably heard of Blackstone before. I think that there's maybe no one more notorious within the housing space than Blackstone but there are all kinds of other similar funds of different size, scale. And I've been fascinated to see particularly over this summer the ways in which they partner with one another. And I guess just one other reflection I'll offer is what regulations do exist for banks really are absent when it comes to private equity companies, when it comes to these large scale institutional investors. So I guess all of the questions that are percolating through my mind right now are what it looks like when private equity is potentially involved in some of the transactions that locks me outlined for us. So one of the things that I always say is the structures of these financial relationships that go into the homes that we own are intentionally confusing and opaque. And I think the question that I get more often than anything else is help me find out who owns this property. The LLC structure is obviously bad because of the ways in which it allows money laundering to take place but also they're in a very basic level when tenants have issues. They simply don't know who to go to or who to hold responsible. I didn't know myself until very recently that LLC laws started in Wyoming as recently as late 1970s and spread to every single other state by the 1990s. So it's actually still a very new structure but it's become so incredibly pervasive. One of the tools that I use to describe this sort of convoluted structure is the low income housing tax credit because it's something that I'm particularly familiar with. So less related to money laundering per se but more related to the ways in which tenants simply don't know who owns their homes. I like to tell a story of a housing authority a meeting that I went to where about 50 black, elderly black tenants of a public-private partnership property were angry that their hot water wasn't working, their elevator had stopped functioning, their doors, their electronic doors weren't functioning properly. There's a long, long list of things that shouldn't have been happening in a building that was less than four years old at that point. And they asked the housing authority who owns their home and who they could hold responsible. And the housing authority actually said to them in response that that's a very complicated question and that there isn't a straightforward answer which is stunning, which is a totally stunning thing for a housing authority to say. So they explained that it's a partnership between the nonprofit, in this case the housing authority, the private property manager and a financial investor, an investor, a financial partner an investor that couldn't be disclosed. And this same structure has come up again and again in research that I've been tasked with doing. I don't know if people saw recently there was an announcement that Blackstone has acquired a portfolio of affordable housing properties from the insurance company AIG. And I actually was asked to help find where these properties are, but it's incredibly difficult. And one of the things that I found recently in a Financial Times article that I'll share a link to is that they're actually a handful of lawsuits between the nonprofit partners and the investment partners over who actually will own these properties long-term and whether or not it's an AIG property or name your nonprofit affordable housing provider property. And these are situations where this nonprofit is the less than 1% owner and the investment company has a 99% stake and they make money off of the actual tax credit itself and through things like depreciation. So they claim that this building is actually decreasing in value over time for tax purposes, but we know in reality that real estate assets to the exact opposite. And I mentioned those just as tangible real-life examples where people have struggled with knowing who to hold accountable. I'll name and share a link to a report that I did last year called Make Them Pay, looking at some of the biggest owners of private equity companies or corporate landlord companies detailing the amounts of money that they grief in windfalls from the federal government, but also pointing to, well, we get a little bit less into in that report, but I think it's important to acknowledge the political relationships that the heads of these companies have with whether it's elected officials, people appointed to regulatory agencies or some of the federal departments. And I think most famously this includes people like Steve Mnuchin, it includes people like, I don't know if folks saw recently Tom Burrock, the head of Colony Capital, a real estate investment trust was actually had charges brought against him for illegally lobbying the Trump administration. The list goes on and on, but it's also, I think that there is a lot of discussion about the relationships between the Trump administration and these real estate executives, but it's also a bipartisan phenomenon. So people like Don Mullen, the head of Predion Partners who's notorious. I looked just yesterday, his company has addicted over 7,000 people during the pandemic recently gave 2.8 million to Democratic candidates actually over several years. I think I am running over time, but I'll just say that these political relationships manifest in tools like the low income housing tax credit and tools like all of the windfall benefits that the industry reached through things like the CARES Act legislation. Like I mentioned, I'll link to a report that I did, but we estimated over 470 billion in tax handouts to the real estate industry by the federal government. So their actual tangible benefit to those political relationships and those financial contributions that get made. Unfortunately, I think I'll have to leave it at that. I could talk about this forever. I'll also include my email address, I'm happy to have more in depth conversations with anyone who wants to talk more about private equity and housing and how it impacts Don Mullen. Great, thank you so much, Sophia. We're going to now switch out to California. Jotsu Rupawa is the organizing and campaigns director with the California Reinvestment Coalition. If you could share what's happening on the ground in California, how these opacity issues are intersecting with the campaigning goals that you have and also what sort of reform opportunities you see on the horizon at the state level in California. Yeah, happy to. Thanks, Ian. Hi, everyone. Really a pleasure to be on this panel with so many awesome folks. All of their work has really lend itself. We call it a gift to our campaign here in California. But I'll start with some introductions. I'm Jotsu Rupawa, as Ian said. I'm the organizing and campaigns director at CRC. I'm going to try and share my screen so you'll let me know how it's working. Let's see, can I present this? Great. So I'll go do a brief overview of some of the issues that we're seeing with this opacity as presenters before me have outlaid, sorry for the repetition. But I have some graphics that contextualize some of this information, which I hope you'll find helpful. But before I dive into that, I just wanted to tell you a little bit more about who we are in case you're not familiar. The California Reinvestment Coalition is a true coalition. We're about 35 years old and our members are organizations. Our executive director calls them the financial, first financial responders in times of crisis. They're CDFIs, tenants rights organizations, fair housing agencies, portable housing developers, legal service agencies, small business technical assistance providers, and sometimes organizations that do multiple things. We also have folks who are policy shops, specifically working to look at changing either regional or statewide policy as related to all of these issues. So there's a lot of common cause amongst our folks. So we've talked a lot about how large corporate landlords hide their assets. And I just kind of wanted to show you, this is one large corporate landlord, they're a slumlord in Los Angeles County. And one of our member organizations, Strategic Actions for a Just Economy, if you don't know them, you should, they're awesome. Their researchers and organizers have spent months and months trying to pull together information from the tenants, a slip of tongue from the managers about who the owners are and actually digging through paperwork that the Department of Health here in Los Angeles has or the eviction courts have to really piece together how M&M asset management is actually connected to middle, Mark Middle, who is Swami International and all the other various entities. So you can see that there are a ton of LLCs. There might actually be more that our folks have just not connected to. And then here's another person, Jeffrey Palmer. So Chuck here, your work, Cashing in Our Homes, is an awesome report. Another gift to this campaign, profile Jeffrey Palmer. He's a special kind of slumlord, a real piece of work. Currently he is suing the city of Los Angeles for lost millions, millions lost because of eviction moratorium. So he would have rather evicted his tenants during the pandemic and is suing the city for making him not do that. Of course, the state of Los Angeles, California has created a rent debt fund, which means he can actually have his tenants apply for payment to their landlord. But I think knowing the neighborhood that Jeffrey Palmer sits in as Lakshmi was laying out and as Sophia pointed to, a lot of the times these landlords, including Jeffrey Palmer's is mostly interested in earning from the equity in the property. So making repairs or having any stability in his properties is not his incentive at all. In fact, in Los Angeles where there's rent control, there's something called eviction decontrol that kicks in. So when you kick out a tenant that's been living in a property for a long time, you may have only been able to raise their rent three to 5% year to year, but once you kick them out, the new tenant will pay whatever it is that you're charging. Subsequent increases are subject to the rent stabilization, but there is that bump in income that landlords have and Jeffrey Palmer certainly want to maximize all the things. But again, these are different LLCs that Sage has been able to identify that Jeffrey Palmer works under, but as you can see, there may be more given how many there are. We've also talked about the pathologies of corporate landlords a little bit, but again, I wanted to show you another visual. This is a map of Los Angeles city and I hope you can kind of read it. I had to crop off the title there, but the dots are Ellis Act evictions and the, sorry, am I looking at the right map? No, the dots are rent stabilized. Yes, the dots are evictions and the colors are where there are rent stabilized units. So what we wanted to show you is that corporate landlords are indeed aggressive evictors. You can see from this data that where there are large concentrations of corporate landlords, they're certainly evicting people regardless of the fact that they are rent controlled properties. In fact, Veritas, another landlord who cashing in our homes, I think also profiled. Their model is to specifically use taxpayer dollars. So tax incentives from the federal government, from sometimes from the state government also and by rent controlled properties. Rent controlled properties are slightly cheaper in the market than another building. And then they do all that they can to kick tenants out. They employ tactics like repairs, like never ending repairs, dust and debris that sits in the hallways. It makes children sick. It makes old people sick. Often rent control properties, particularly in cities like San Francisco have tenants who are older tenants. They may be on fixed income. And so you can imagine dust and debris sitting in the hallway is really a nuisance for folks with low mobility, sensitive lungs and other needs. So it really is a very cruel way in which these landlords are operating and given how much property they have and how it's hidden, they're sort of operating with a ton of impunity. So here again, another data set just showing DPH complaints. So Department of Public Health in Los Angeles is who registers all the habitability complaints. So we find that just comparing notes on where the corporate owners are and where the terrible habitability complaints are, you can see some of that. So our campaign here in California is called Homes for Families. It's a corporate, we call it the corporate monopoly, excise tax and transparency effort. So in California, this may be a better sort of image to look at. In California, corporate landlords go to the Secretary of State's office to create their LLCs. And in conversation with SOS, we actually found that it would be more expensive for them to create a database that was hidden. So with the Federal Corporate Transparency Act, we're so grateful for fact, for sharing all the information. We've really learned a lot from the federal effort. And one of the things we learned is that it's actually too bad that the information is not publicly accessible. So in California, for the sake of really getting at this impunity that corporate landlords enjoy, we wanted this information about their LLC webs to be publicly known so that tenants themselves or tenants rights organizations, policy, people who are interested in making policy. So government local legislators can actually study and know what is the concentration in their district of corporate ownership. They hear these anecdotal information about, hey, all these buildings are owned by Veritas or hey, here's a map. And they'll always say, is this it? Like can you give us a guarantee that this is what it is? Because real estate does lobby and they're really good at sort of stirring the pot and casting the shadow of doubt. So without transparency, it is hard to be able to say, yes, we're a hundred percent sure that this is what the Irvine company owns or this is what Jeffrey Palmer all owns, right? So these landlords, including Veritas, go to local jurisdictions and will say, actually, I don't own this property, prove it. So in a place like San Francisco and Los Angeles where tenants rights advocates have successfully won an eviction defense program, taxpayer dollars are supporting tenants in eviction court. And sometimes there are cases that go on forever and mostly because the landlord shows up to court and says, actually, I don't own this property. I don't know why I'm being pulled into this effort. Or, oh, look, I'm a small landlord. I just have these two properties. Sorry, I'm learning the ropes. I don't know what it is that I needed to do. I'll fix it. And all the while, their whole large operation is to go have, pay middle wages to some Schmuck who will go to court and claim to be the owner and claim to be a mom and pop landlord. And it's actually ruining the reputation of mom and pop operations. What our research found is that mom and pop operations are better. They're not without fault. They're not always perfect, but that they do care more about their tenants and they will not do things like let little children get sick in their properties if they know what is happening, particularly if there are government funding that's available to improve their properties. They're interested in improving their properties. So what we're proposing is that the Secretary of State Office create a publicly accessible database of LLCs with their beneficiary owners listed, such that Jeffrey Palmer would appear on every single LLC form. And that all his tenants would be able to know that their property is ultimately also owned by Jeffrey Palmer. So that the Los Angeles County and city will know what, how much property does he really own in this, in their areas. And we're also proposing that there be an excise tax levied to essentially disincentivize, as Lakshmi was talking about and as Sophia is saying, like there is a commodification of land that has happened that is ultimately really problematic. And we can't solve that with just one policy, but what we are saying is that corporate landlords buying up single family homes, the way they're buying up single family homes is actually stripping opportunity away from low and moderate income families to find financial stability today and provide generational wealth for their next generations to come. It is one way in America in which people really do find that kind of stability. So if corporate landlords are picking up all the property in these transit oriented areas where there's suddenly a big influx of taxpayer dollars, it is the families who have lived in those neighborhoods for a really long time who ought to benefit from that. So those families being displaced and not being able to buy it by in is tremendously problematic and it's new red lining, right? So what we're saying is that we're proposing a tax for corporations who own 10 single family homes. So the threshold is quite low, but in a state like California, 10 single family homes that you're still a gazillionaire or 25 buildings, it was a little bit cumbersome for us to try and figure out units. So what we've currently started off where they're saying 25 buildings, we just wanted to be explicit to legislators that we're not trying to capture small mom and pops. If they're a landlord themselves or they have friends who are landlords, this is not that. And what we are proposing some calculation with what we already know would raise a billion dollars annually via this tax and we would like that money to create a homes for family fund, which would go towards rental assistance and relief, continued need in California, mortgage assistance programs, because as I mentioned, we're really interested in providing stability to BIPOC communities that have not had the same access to capital for decades and other housing programs, including legal services. So I'll stop there, see if there may be any questions about what we're doing or what we're seeing. I also just wanted to add two other things, actually, sorry. One, without knowing who corporate landlords are, we also cannot address any fair housing concerns. So the topic of this webinar, like one of the huge worries that we cannot actually substantiate without more information is this possible trend that with these aggressive evictors, perhaps they are only evicting Black families or Spanish-speaking Latino families. We don't know and we cannot show that until we actually have this information. And the other issue is, as Sophia mentioned, banks. So Bank of California is at the moment going through a merger and we're opposing their merger application or in conversation with them about a community reinvestment, their plan. At the moment, they have gone to the federal regulators and claimed that they're meeting their CRA obligation by creating access to capital for multifamily landlords. So they're essentially saying, look, we provide financing to landlords in this low-income neighborhood in Los Angeles, we're meeting our obligation. And you see, without transparency about how are these LLCs actually connected to other LLCs who exist, we can't see clearly if they're financing slumlords. But we made an attempt because we do have tenants rights organizing organizations on the ground. We sifted through some data of who they're providing mortgages to and who we know are slumlords and there are matches. We know that some of the people that they're providing access to capital to are slumlords. So we're really interested in the role that banks can play, they know this information, right? Like landlords have to provide information about who the beneficiary owner is when they ask for capital. So we'd like that same transparency actually to be available to the public so that all of this could be studied. Okay, now I'm really stopping. Thank you so much. There's just so much fascinating information to share. Chuck, in a couple of minutes, could you talk about some of the other ways that local municipalities are responding to this issue of lack of transparency in the real estate sector? And then we really do want to turn it over to the audience to have some opportunity for Q&A. Yeah, I'll be brief because I'd like to hear questions as well. But I'll just say, I think it's very exciting that housing organizers, grassroots housing organizers are coming together with transparency activists because we see the range of harms because of anonymous ownership. And I think the solutions that Jyotsaroop proposed, the California state legislation is exactly the right direction. What we're seeing on the ground is sort of invisible disrupted forces on our affordable housing systems, on our housing markets. There's old fashioned gentrification driving up the cost of housing. There's the transition from to short-term rental, apartments being taken off the market for short-term rental. There's what Sophia described, this kind of transition to corporate ownership and the growing corporatization of real estate ownership. And then there's what Lakshmi writes about, which is the global capital coming into our communities with a sort of set of different interests. They're trying to purchase real estate, not to own it as housing, but as sort of a place to park capital, to launder funds, that's wealth storage. But the thing that unites all those things is that the anonymous ownership is the harmful ownership form. And I'm excited by California initiative and all I'll just add is I think there's an appetite more and more in municipalities to also know who's buying our neighborhoods. Even without understanding sort of the GTO and the sort of work of FinCEN, there's an appetite for public registries. Look, people buy property, real property is a different category of asset. It is rooted, it is land, it is in place. And a local jurisdiction has the deeding authority and there's already the registries exist to register properties. And there's a couple of property attorneys that I've worked with who are saying, look, you could say here in Boston and Suffolk County at the registry of deeds, if you want to have standing in our legal system, if you want to address a lien, if you will have a tenant dispute, you need to have your disclosure of beneficial ownership clear if you wanna have standing. So in addition to, I think the work at the national level to expand GTO that Lakshmi talks about, and I think states with public registries, I think municipalities should also be looking at how do we unmask anonymous owners? How do we understand? I think Judt Sirub said it perfectly. How do we help policymakers get the information they need to protect our communities from these harms? If you don't know who's buying your community, if you don't know who these invisible forces are, we're not gonna be able to pass reforms to protect tenants and to protect our communities from these outside owners. So I guess I would say there's, I think there's a, we should be looking at both the sort of national but also the sort of bottom up transparency efforts, support and nurture them. I could, if people are interested, I can talk more about that. But I think that that will help us inform whether we should have laws around vacancy, whether we should be concerned about foreign ownership, whether we should levy luxury transfer taxes on high end. Shall we? I think that having that picture will help inform that. So let me stop there because I know there are people probably with really good questions and. Great. Thanks so much, Chuck. That was a really good, I think summation and drawing the threads together of this conversation. Reminder to people, raise your hand or send a question through the Q and A function. I think a question for Lakshmi that I've received is what is your assessment of how Treasury is moving on implementing the Corporate Transparency Act? Do they have the resources and people they need to do it? What is your expectation in terms of the timing to get that done? No, thank you, Ian. And that's that's a great question because, you know, a lot of this is underpinned by the fact that we do need a beneficial ownership registry to start tracking individuals. And it is the best solution we have to target opacity. You know, the big thing that came out in the last couple of months that everyone worked very hard on was the advance notice for rulemaking around the registry, which all of us submitted extensive comments and facts. Submitted a magnum opus of comments, which is 150 page exhaustive comments on it. And I, you know, I think right now we are still in an wait and watch period. We want the rules to see what the regs will look like to see whether they truly capture what the CTA legislation set out to do or they take a much more, you know, narrow approach from, I think, and that would pose for us the cost of concern for all of us within the advocacy space if it were to take a more sort of narrow approach from what the CTA actually envisions. And so at least that's where we are. I think, you know, we are, we still don't really know whether, how far Vincent has worked towards actually, you know, sending out an RFPO inquiring about the building blocks of the registry itself, because, you know, that goes hand in hand with the actual regulations. But the advance notice for rulemaking at least tells us, gives us gave us a lot of room to sort of hopefully advocate, provide our input on areas that we think are critical and important to address so that the final beneficial registry is strong. Because if we have a weak registry, then all of this is meaningless. You know, it's going to stay with us for the next decade or so, because no one's going to change it. So I think working towards and making sure we can really strengthen and make sure we have a strong regulatory or regulations around that CTA, I think is where we've put our efforts to and where we're waiting to see what Vincent will come back in terms of draft regs. Great. We have a question from Musa Tuzener, if you'd like to ask your question. Musa? Do you hear me right now? Yes, we can hear you. Yes. My question is because I'm from Turkey originally, so I'm teaching at the Ghani University, so AML and intelligence classes, but I know that there are many politicians, corrupted politicians, even I'm from Turkey, that they all bring their dirty money. They even, you know, European countries or the United States to buy the property. I think so. Are they right now this, you know, in the, you know, buying the property instead of cash, you know, are they starting to buying with the cryptocurrency? Are they allowed to buy, you know, the property with the cryptocurrency? Because they all invested their money. I heard that. I am hearing that. And it's easy to move that cryptocurrency from one valley to another country. And this time, no banking institution will not be, you know, to involve that part, moving that part, and they never gonna know that how this money from, you know, Turkey or other Iran, some other part to the United States. I'm just curious. I just, you know, how the property works on that. Yeah. So Luxembourg, do you have any thoughts on that or how are cryptocurrencies used in some of these real estate purchases? So I can tell you, because we have a halfway done draft on this subject. So that's why I'm in a position to answer. You can ask me a couple of months ago, maybe not. But yes, so we have seen cryptocurrency used to purchase real estate, whether it's in the US, whether it's in Europe. But for it to sort of truly be an illicit transaction and move title, then you're going to have to have two individuals who only want to transact in crypto. Very often, if the seller still wants a cash payment, you're going to have to convert that into cash in. A lot of the times it does go through a banking system of some kind. A lot of banks sometimes don't, you know, there's a lot of reticence around it. So yes, you know, with any illegal scheme, there are opportunities. But what I will say is that why will you choose a difficult option like cryptocurrency? When there is, you have, it's carte blanche to use cash and buy real estate. It is the infinitely easier option. And so yes, you often see like cryptocurrency nuts or like, ah, I have cryptocurrency, let me buy property. I'm going to go against the established system. So you see a lot of those kinds of purchases, at least the examples we've collected. But I think if you're a corrupt individual or criminal actor, the reason you migrate to crypto is when the existing system has safeguards that would prevent you from laundering your money. There are no sufficient safeguards. So you choose the easier part. And the easier part is to move your money through cash to the financial system and buy property because no one's going to ask you a question when you buy property. No one's going to ask, Lakshmi, you work in civil society. How do you have $100 million to buy this hotel? And you know, till we get to that place, cryptocurrency is not as large or threat at least in this sector. Great, thank you. We have another question that was submitted that maybe Sophia or Joseph, you might have an answer to. The question is, do public pension funds or quote unquote responsible investors disclose their property portfolios and beneficial ownership already to show it can be done? Could they be leaders? So the mention was made of CalPERS, church investors or others, or do they collude with irresponsible and opaque investors? I'm happy to share my reflections and then just sort of if there's anything you want to add, please do. From the research I've done, it's been incredibly difficult. I think much of what I've had to do is actually going in the opposite direction. So taking a property or set of properties and trying to find out which pensions are actually invested. And it's been incredibly time-insensitive to try and do that because what you have to do is look at the funds that actually acquired a particular property. So I'll give one example. I was looking at ARI's Global Management, a massive private equity company, I think the third biggest in the world. And I had to find a very particular fund in their massive portfolio of funds and then look at which public pensions were invested in that particular fund. So it's incredibly difficult. You have to have access to these proprietary databases that are fabulously expensive to actually be able to find some of this information. I have not seen anywhere in any of my work, excuse me, where pensions have really set the standard for what it could look like to disclose ownership. And I think it's been to the contrary even when I've looked at pension agendas, portfolios, things like that, they'll name something like ARI's Single Family Fund, XII or what have you. And it's difficult then to go the other direction and find out, okay, so where are the thousand or so homes that that particular fund and that particular pension own. So sadly, no, but I think, as entities that are publicly accountable that represent the pensions of either public sector workers or other unionized employees. I do think there's potential, it all will take organizing, but I think there's potential to try and make that push, but I think there's a strategic question to whether or not that makes sense and or if there's this broader federal avenue that exists that could be leveraged. Maybe it's a combination of both. Great, Judd, do you have any thoughts on this question? Yeah, just a quick note on that is, actually the state of California doesn't ask that question. There's no place to, that says beneficiary owner blank. So what we're asking is that on the LLC registration form, SOS actually create that field and require people to provide that information and define beneficiary owner the same way that the Corporate Transparency Act that the fact coalition pushed for defined which is 25% ownership or substantial control. So naming a human being a natural person is at the moment not required. Okay, we have a question from Zoe Ryder who's a fact coalition member with the Pogo. And she asks, well, she says the Corporate Transparency Act is a registry, we'll set up a registry that's really only available to the financial crime enforcement network, law enforcement agencies and financial institutions. This is obviously a huge victory, but it has limited impact for advocacy since it's not a public registry at the national level. So Zoe's question is, how do we move towards public registries? Do we have a better chance pushing at the local and state level? Also what happened to a New York state law regarding beneficial ownership transparency in real estate? I don't know if anybody on the panel has information there. And maybe Chuck, you could talk to that. Judd Swaroop, maybe you could mention the California assembly legislation and your campaign to get that over the finish line. Chuck. Oh, sorry, I was on New York. It's fascinating because it was really when New York passed an LLC disclosure law, I would say almost by accident, was upstate legislators who were concerned about sort of illicit auxiliary units and single family houses and that sort of thing. It passed this law, it was somewhat modeled after the city of New York's not public transparency registry. And what happened I think is the real estate industry mobilized to make sure that it would not be a public registry. And I think that is one of the challenges is at the state and local level, real estate really does capture the political system, the fact that we were able to get federal legislation is pretty significant. But it's all the more important that we build constituencies of groups that can push for transparency from the other side. So that's what happened unfortunately in New York. There really wasn't a countervailing organized force to defend the public registry. Yeah, that sounds right. In California, AB 1199, the legislation that we've pushed forward is facing a lot of challenges. Similarly, I think real estate is a very powerful lobby. They create a lot of confusion, push forward a lot of inaccurate narratives. And yeah, they're successful in their agenda. So I think Chuck, you're right. Like there has to be a groundswell and a demand for this transparency from a diverse coalition, people needing it. So same, that's why we're really pushing forward this conversation about, hey, this is good information just for research. And it helps tenants, but if you don't care about poor people like you should just care about research. So we'll take one more question before we wrap up. This question is from Malini Raghunathan who says, I've just finished writing a book on real estate corruption and anti-corruption activism in Indian cities, which as the panelists probably now contain some of the most lucrative land markets in the world. The stories around corruption reveal the global nature of corruption. For example, offshore shell companies, criminal rackets, money laundering, laden grabs, et cetera, but also that quote unquote corrupt real estate practices are not always quote unquote illegal. For example, fast track foreign direct investment. Two questions. Have any of the panelists investigated how corruption in the global South cities affect corruption in the US? And two is corruption in your understanding always quote unquote illegal. Any comments on that? Maybe Lakshmi, do you have some thoughts? No, I'm happy to. And that's a great question, Malini. So when we looked at the US, because you often see the US or the UK or Canada often act as destinations for a lot of illicit money. But also as you see with money laundering and corruption, there are, you can never separate money laundering from history and geography. And that's reflected in money laundering trends and patterns. So in the US, for example, we see a lot of that illicit money. You had money coming in from India. You had the nearer of Modi scandal was the Diamond Merchant scandal, India's largest trade based money laundering scandal. And also the Subrata Roy from India's largest Ponzi scam by the New York Plaza, an iconic building. No one asked questions. And he looped at India Square to be able to put all of that money into the Plaza. No one raised a question. So yes, you do see that migration. But at least when you're talking about India, we also saw a lot of money from India and Pakistan going to the UK, more so than we saw in the US. And that makes sense given the historical relationship there. Now, especially when you talk about corruption. Corruption is complex because you're just looking at it as a lawyer and it's legal sense. Corruption is bribery embezzlement. But corruption is truly a sociological behavior. It is nepotism. It is undue influence. And so it is not always legal. Sometimes you recognize that it's incorrect behavior. And you're working to make that illegal and therefore corrupt. I don't think we were specifically looked at fast track foreign direct investment. But I think what would be especially interesting in the South Asian context or even in the East Asian context is using FDI as a way to do round tripping of finances, which is a preferred money laundering technique and a way to move ill-gotten gains through South Asian economies in general. I'm happy to sort of go over this and talk about this in greater detail as well. Great. Thank you. So I'll use the chair's prerogative for one final question. And that goes to Lakshmi. If we had a conversation like this a year from now, what would you hope Treasury would have done by then to address this problem? Oh, that's that's hope. I'm very optimistic always. But I would hope that we have concrete building blocks towards a beneficial ownership registry. We have a rulemaking that is that's happened to make sure that the GTOs have been converted essentially to become a national regime. And because we've talked so much about the role of private equity and hedge funds. And I know a lot of us in this space are working towards making sure that investment advisors are also accountable and have to do due diligence. Those would be the three things I'd like to see at least have substantive progress on. And it's not just asks, but actually we've seen text. We're seeing words around it. That would be my hope. I think if we all work together, we can get there. And I want to thank all of our panelists. I don't think we could have had a better panel to discuss these issues. I think we've unearthed a lot of connections that probably haven't been discussed in this way before. I'm really stimulated by the conversation. I hope that we can continue to work together with your organizations and with other organizations and try to bridge the divides between some of the groups that are working on these sort of quote unquote, foreign policy or federal level issues with the work that's happening at the grassroots level. And we'll also be sure to share with participants the recording of this event and resources and contact information for our panelists. So let's keep this conversation going and thank you very much for everybody in your participation. Thanks to Fact for hosting. Thank you all. Thank you so much. Bye. Thank you for being a great moderator, Ian. Thanks.