BestFSBOGuide.com team
Carmen Ortiz
Americas research editor
One hemisphere, two incompatible ways of making a sale official. North of the Rio Grande a title or escrow company handles the money and a recorded deed settles ownership. South of it, a public notary drafts the escritura and the property registry decides when the transfer is real. Carmen edits both halves of that split for the site, which mostly means refusing to let the vocabulary of one system get borrowed to explain the other.
An escribano is not a notary in the American sense, and a US notary is not remotely an escribano. Getting that wrong is how a guide talks a Mexican seller into expecting a title company or leaves an Argentine buyer unprepared for how much of the transaction runs through one official’s office. Carmen’s coverage keeps the two models apart on the page, which is harder than it sounds, because the English words overlap and the legal weight does not.
The other half of the job is jurisdiction. The United States alone is fifty answers to questions like who runs the closing table and what a seller must disclose, and Canada varies province by province, with Quebec running on its own civil-law footing. Mexico adds the restricted zone near the coasts and borders, where a foreign buyer holds through a bank trust rather than in their own name.
Since the 2024 commission settlement reshaped US practice, she has been rechecking the American cost figures more often than the rest, because that is where sellers are most likely to be working from advice that was accurate two years ago.
Areas of focus
- Covers US and Canadian settlement and title practice alongside Latin American notary and registry procedure
- Follows transfer and capital-gains treatment across US states, Canadian provinces, and Latin America
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