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Two things jump out at me here. First, this is a spot where the reach of the USA PATRIOT Act is just enormous. It affects every single real estate transaction in the nation. From an administration that purports to be concerned about protecting state and local power from the reach of the federal government, this is an extraordinary foray into what has always been understood to be a core matter of state and local concern--transactions in real property.
Second, the USA PATRIOT Act here seems to tamper with the attorney-client relationship in a fundamental way. Not only does the law create an obligation for lawyers to rat on their own clients, it also creates an obligation for lawyers to conceal things from their own clients.
Well, I wasn't too concerned because I didn't read about it until this moment. Now I am concerned.