Tag Archives: fincen

Texas Bank Penalized $2 Million for Violations of Anti-Money Laundering

FinCEN assesses civil money penalty against Lone Star National Bank (Lone Star) of Pharr, Texas for willfully violating the Bank Secrecy Act

By Jeff Sorg, OnlineEd Blog

(November 2, 2017)

canstockphoto18625424 compliance street sign(WASHINGTON, D.C.) – The Financial Crimes Enforcement Network (FinCEN) today announced the assessment of a $2 million civil money penalty against Lone Star National Bank (Lone Star) of Pharr, Texas for willfully violating the Bank Secrecy Act (BSA). The action underscores the dangers that institutions face when taking on international correspondence activities without properly equipping themselves to manage such business. As noted in FinCEN’s assessment, among other lapses, Lone Star failed to comply with section 312 of the USA PATRIOT Act, which imposes specific due diligence obligations with respect to correspondent banking.

Many of the lapses in Lone Star’s BSA compliance were previously covered in an earlier action by the Office of the Comptroller of the Currency (OCC), but FinCEN’s action focusing on the bank’s 312 violations specifically highlights the need for a financial institution to avoid taking on international business for which it is not prepared. Lone Star’s Mexican financial institution customer was moving millions of dollars through Lone Star in a manner inconsistent with the parameters of a relationship which, at the outset, required greater scrutiny. Lone Star failed to identify and consider public information about the foreign bank owner’s alleged involvement in securities fraud. It also failed to verify the accuracy of assertions by the foreign bank with respect to source of funds, purpose of the account, and expected activity.

“Lone Star plainly failed to ask obvious due diligence questions in connection with its foreign bank account relationship, and did not follow up on inconsistencies in answers to the questions that it did ask,” said FinCEN Acting Director Jamal El-Hindi. “Notwithstanding the fact that the OCC already fined the bank, FinCEN’s assessment takes into account the penalties specifically applicable under FinCEN’s Section 312 authority. Smaller banks, just like the bigger ones, need to fully understand and follow the 312 due diligence requirements if they open up accounts for foreign banks. The risks can indeed be managed, but not if they are ignored.”

With respect to many of the deficiencies noted in FinCEN’s assessment, the OCC entered into a Consent Order and a Memorandum of Understanding with Lone Star in 2012. Lone Star continued to have severe programmatic anti-money laundering (AML) deficiencies through 2012, 2013, and 2014. As a result, in 2015, the OCC issued a Consent Order for a Civil Money Penalty in the amount of $1 million against Lone Star. Lone Star’s previous penalty payment to the OCC will be credited to FinCEN’s assessment and the bank will pay an additional $1 million to satisfy its obligation to FinCEN.

FinCEN recognizes that Lone Star has expended considerable resources to respond to the findings regarding its BSA program and to promote compliance with the OCC’s Consent Order. Lone Star is no longer engaging in the correspondent banking activities for which it was ill prepared. The bank has contracted outside consultants to conduct independent testing, conduct customer due diligence and suspicious activity lookbacks, and has expanded its BSA compliance organization.

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For more information about OnlineEd and their education for real estate brokers, principal brokers, property managers, and mortgage brokers visit www.OnlineEd.com.

All information contained in this posting is deemed correct as of the date of publication, but is not guaranteed by the author and may have been obtained from third-party sources. Due to the fluid nature of the subject matter, regulations, requirements and laws, prices and all other information may or may not be correct in the future and should be verified if cited, shared or otherwise republished.

OnlineEd® is a registered Trademark

Financial Crimes Enforcement Targets Shell Companies Purchasing Luxury Properties

Geographic Targeting Orders expanded to include Honolulu, Hawaii 

OnlineEd Blog

(August 23, 2017)

canstockphoto5735968- luxury building(WASHINGTON, Aug. 22, 2017/FinCEN) The Financial Crimes Enforcement Network (FinCEN) today announced the issuance of revised Geographic Targeting Orders (GTOs) that require U.S. title insurance companies to identify the natural persons behind shell companies used to pay for high-end residential real estate in seven metropolitan areas.  Following the recent enactment of the Countering America’s Adversaries through Sanctions Act, FinCEN is revising the GTOs to capture a broader range of transactions and include transactions involving wire transfers.  FinCEN also expanded the GTOs to include transactions conducted in the City and County of Honolulu, Hawaii.

In addition, FinCEN today published an Advisory to provide financial institutions and the real estate industry with information on the money laundering risks associated with real estate transactions, including those involving luxury property purchased through shell companies, particularly when conducted without traditional financing.  Such transactions are vulnerable to abuse by criminals seeking to launder illegal proceeds and mask their identities.  The Advisory provides information on how to detect and report these transactions to FinCEN.

“Through this advisory and other outreach to the private sector, FinCEN, industry, and law enforcement will be better positioned to protect the real estate markets from serving as a vehicle to launder illicit proceeds,” said FinCEN Acting Director Jamal El-Hindi.  “FinCEN also thanks Congress for its modification of the Geographic Targeting Order authority, the first use of which will enable FinCEN to collect further information to combat the potential misuse of shell companies to purchase luxury real estate.”

In January 2016, FinCEN issued GTOs to require U.S. title insurance companies to report beneficial ownership information on legal entities, including shell companies, used to purchase certain luxury residential real estate in Manhattan and Miami—specifically, luxury residential property purchased by a shell company without a bank loan and made at least in part using a cashier’s check or similar instrument.  In July 2016 and February 2017, FinCEN reissued the original GTOs and extended coverage to all boroughs of New York City, two additional counties in the Miami metropolitan area, five counties in California (including Los Angeles, San Francisco, and San Diego), and the Texas county that includes San Antonio.

Within this narrow scope of real estate transactions covered by the GTOs, FinCEN data indicate that about 30 percent of reported transactions involve a beneficial owner or purchaser representative that was also the subject of a previous suspicious activity report.  This corroborates FinCEN’s concerns about this small segment of the market in which shell companies are used to buy luxury real estate in “all-cash” transactions.  In addition, feedback from law enforcement indicates that the reporting has advanced criminal investigations.  The expanded GTOs will further help law enforcement and inform FinCEN’s future efforts to assess and combat the money laundering risks associated with luxury residential real estate purchases.

FinCEN appreciates the continued assistance and cooperation of the title insurance companies and the American Land Title Association in protecting the real estate markets from abuse by illicit actors.

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For more information about OnlineEd and their education for real estate brokers, principal brokers, property managers, and mortgage brokers visit www.OnlineEd.com.

All information contained in this posting is deemed correct as of the date of publication, but is not guaranteed by the author and may have been obtained from third-party sources. Due to the fluid nature of the subject matter, regulations, requirements and laws, prices and all other information may or may not be correct in the future and should be verified if cited, shared or otherwise republished.

OnlineEd® is a registered Trademark

FinCEN Renews “Geographic Targeting Orders” to Identify High-End Cash Buyers in Six Metros

FinCEN is covering title insurance companies because title insurance is a common feature in the vast majority of real estate transactions.

OnlineEd Blog

(March 1, 2017) –  WASHINGTON—The Financial Crimes Enforcement Network (FinCEN) today announced the renewal of existing Geographic Targeting Orders (GTO) that temporarily require U.S. title insurance companies to identify the natural persons behind shell companies used to pay “all cash” for high-end residential real estate in six major metropolitan areas. FinCEN has found that about 30 percent of the transactions covered by the GTOs involve a beneficial owner or purchaser representative that is also the subject of a previous suspicious activity report. This corroborates FinCEN’s concerns about the use of shell companies to buy luxury real estate in “all-cash” transactions.

“These GTOs are producing valuable data that is assisting law enforcement and is serving to inform our future efforts to address money laundering in the real estate sector,” said FinCEN Acting Director Jamal El-Hindi. “The subject of money laundering and illicit financial flows involving the real estate sector is something that we have been taking on in steps to ensure that we continue to build an efficient and effective regulatory approach.”

The GTOs renewed today include the following major U.S. geographic areas:  (1) all boroughs of New York City; (2) Miami-Dade County and the two counties immediately north (Broward and Palm Beach); (3) Los Angeles County; (4) three counties comprising part of the San Francisco area (San Francisco, San Mateo, and Santa Clara counties); (5) San Diego County; and (6) the county that includes San Antonio, Texas (Bexar County). The monetary thresholds for each geographic area can be found in this table. A sample GTO, which becomes effective for 180 days beginning on February 24, 2017, is available here.

FinCEN is covering title insurance companies because title insurance is a common feature in the vast majority of real estate transactions. Title insurance companies thus play a central role that can provide FinCEN with valuable information about real estate transactions of concern. The GTOs do not imply any derogatory finding by FinCEN with respect to the covered companies. To the contrary, FinCEN appreciates the continued assistance and cooperation of the title insurance companies and the American Land Title Association in protecting the real estate markets from abuse by illicit actors.

[Source: FinCEN media release]

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For more information about OnlineEd and their education for real estate brokers, principal brokers, property managers, and mortgage brokers, visit www.OnlineEd.com.

All information contained in this posting is deemed correct as of the date of publication, but is not guaranteed by the author and may have been obtained from third-party sources. Due to the fluid nature of the subject matter, regulations, requirements and laws, prices and all other information may or may not be correct in the future and should be verified if cited, shared or otherwise republished.

OnlineEd® is a registered Trademark

FinCEN Penalizes California Bank for Egregious Violations of Anti-Money Laundering Laws

Merchants failed to establish and implement an adequate anti-money laundering (AML) program

OnlineEd Blog

gavel money(February 28, 2017) – WASHINGTON—The Financial Crimes Enforcement Network (FinCEN) today announced the assessment of a $7 million civil money penalty (CMP) against Merchants Bank of California of Carson, CA for willful violations of several provisions of the Bank Secrecy Act (BSA). The Office of the Comptroller of the Currency (OCC), the primary federal regulator of Merchants, has identified deficiencies in the Bank’s practices that resulted in violations of previous consent orders entered into by Merchants, as well as other violations. The OCC simultaneously assessed a $1 million CMP against Merchants for these violations.

Merchants failed to (a) establish and implement an adequate anti-money laundering (AML) program, (b) conduct required due diligence on its foreign correspondent accounts, and (c) detect and report suspicious activity. Merchants’ failures allowed billions of dollars to flow through the U.S. financial system without effective monitoring to adequately detect and report suspicious activity. Many of these transactions were conducted on behalf of money services businesses (MSBs) that were owned or managed by Bank insiders who encouraged staff to process these transactions without question or face potential dismissal or retaliation. Bank insiders directly interfered with the BSA staff’s attempts to investigate suspicious activity related to these insiderowned accounts.

“The banking of money services businesses is important to the global financial system, and we believe that banks can mitigate the risks associated with such businesses, just as they do with other customers,” said FinCEN Acting Director Jamal El-Hindi. “But here we had an institution run by insiders essentially to provide banking services to MSBs that the insiders owned, combined with directions from Bank leadership to staff to ignore BSA requirements with respect to those MSB customers and others. It is certainly not an acceptable way to bank MSBs.”

Merchants specialized in providing banking services for check-cashers and money transmitters. However, it provided those services without adequately assessing the money laundering risks and without designing an effective AML program. Merchants also provided its high-risk customers with remote deposit capture services without adequate procedures for monitoring their use.

Merchants failed to provide the necessary level of authority, independence, and responsibility to its BSA officer to ensure compliance with the BSA as required, and compliance staff was not empowered with sufficient authority to implement the Bank’s AML program. Merchants’ leadership impeded BSA analysts and other employees from investigating activity on transactions associated with accounts that were affiliated with Bank executives, and the activity in these accounts went unreported for many years. Merchants’ interest in revenue compromised efforts to effectively manage and mitigate its deficiencies and risks.

In addition, Merchants banked customers located in several jurisdictions considered to be highrisk but did not identify these customers as foreign correspondent customers and therefore did not implement the required customer due diligence program. In a three-month period, Merchants processed a combined $192 million in high-risk wire transfers through some of these accounts.

The Bank’s payment of the $1 Million OCC penalty will be credited towards the satisfaction of the FinCEN penalty. FinCEN’s settlement with a financial institution does not preclude consideration of separate enforcement actions that may be warranted with respect to any financial institution or any partner, director, officer, or employee of a financial institution.

FinCEN seeks to protect the U.S. financial system from being exploited by illicit actors. Its efforts focus on compromised financial institutions and their employees, significant fraud, thirdparty money launderers, transnational organized crime and security threats, and cyber threats. FinCEN has a broad array of enforcement authorities to target both domestic and foreign actors affecting the U.S. financial system.

[Source: FinCEN media release]

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For more information about OnlineEd and their education for real estate brokers, principal brokers, property managers, and mortgage brokers, visit www.OnlineEd.com.

All information contained in this posting is deemed correct as of the date of publication, but is not guaranteed by the author and may have been obtained from third-party sources. Due to the fluid nature of the subject matter, regulations, requirements and laws, prices and all other information may or may not be correct in the future and should be verified if cited, shared or otherwise republished.

OnlineEd® is a registered Trademark

FinCEN Expands Reach of Real Estate “Geographic Targeting Orders” for Title Insurance Companies

Geographic Target Orders are Helping Identify Unlawful Cash Purchases of Real Estate

By Jeff Sorg, OnlineEd Blog

canstockphoto28782162cash sale(July 28, 2016) – Geographic Targeting Orders (GTO) that will temporarily require U.S. title insurance companies to identify the natural persons behind shell companies used to pay “all cash” for high-end residential real estate in six major metropolitan areas. FinCEN remains concerned that all-cash purchases (i.e., those without bank financing) may be conducted by individuals attempting to hide their assets and identity by purchasing residential properties through limited liability companies or other opaque structures. To better understand this vulnerability, FinCEN issued similar GTOs earlier this year covering transactions in Manhattan and Miami-Dade County, Florida. The GTOs announced today will expand upon the valuable information received from the initial GTOs.

The initial GTOs are helping law enforcement identify possible illicit activity and informing future regulatory approaches. In particular, a significant portion of covered transactions has indicated possible criminal activity associated with the individuals reported to be the beneficial owners behind shell company purchasers. This corroborates FinCEN’s concerns that the transactions covered by the GTOs (i.e., all-cash luxury purchases of residential property by a legal entity) are highly vulnerable to abuse for money laundering. Federal and state law enforcement agencies have also informed FinCEN that information generated by the GTOs has provided greater insight into potential assets held by persons of investigative interest and, in some cases, has helped generate leads and identify previously unknown subjects.

“The information we have obtained from our initial GTOs suggests that we are on the right track,” said FinCEN Acting Director Jamal El-Hindi. “By expanding the GTOs to other major cities, we will learn even more about the money laundering risks in the national real estate markets, helping us determine our future regulatory course.” To build on the useful data generated thus far, the GTOs announced today include the following major U.S. geographic areas: (1) all boroughs of New York City; (2) Miami-Dade County and the two counties immediately north (Broward and Palm Beach); (3) Los Angeles County, California; (4) three counties comprising part of the San Francisco area (San Francisco, San Mateo, and Santa Clara counties); (5) San Diego County, California; and (6) the county that includes San Antonio, Texas (Bexar County). The monetary thresholds for each geographic area can be found in this table. A sample GTO, which becomes effective for 180 days beginning on August 28, 2016, is available here.

FinCEN is covering title insurance companies because title insurance is a common feature in the vast majority of real estate transactions. Title insurance companies thus play a central role that can provide FinCEN with valuable information about real estate transactions of concern. The GTOs do not imply any derogatory finding by FinCEN on the covered companies. To the contrary, FinCEN appreciates the continued assistance and cooperation of the title insurance companies and the American Land Title Association in protecting the real estate markets from abuse by illicit actors.

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For more information about OnlineEd and their education for real estate brokers, principal brokers, property managers, and mortgage brokers, visit www.OnlineEd.com.

All information contained in this posting is deemed correct as of the date of publication, but is not guaranteed by the author and may have been obtained from third-party sources. Due to the fluid nature of the subject matter, regulations, requirements and laws, prices and all other information may or may not be correct in the future and should be verified if cited, shared or otherwise republished.

OnlineEd® is a registered Trademark

Financial Crimes Enforcement Network Orders Title Companies to Identify Cash Buyers

Geographic targeting orders take aim at real estate secrecy in Manhattan and Miami

By Jeff Sorg, OnlineEd Blog

stack of 100 dollar bills(January 14, 2016) – The Financial Crimes Enforcement Network (FinCEN) has issued Geographic Targeting Orders (GTO) to require certain title insurance companies to identify the natural persons behind companies used to pay all cash for high-end residential real estate in the Borough of Manhattan in New York City, New York, and Miami-Dade County, Florida. FinCEN is concerned that all-cash purchases might be conducted by individuals trying to hide their assets and identity by buying residential properties through limited liability companies (LLCs)or other opaque structures. To collect information about this potential money laundering vulnerability, FinCEN is requiring certain title insurance companies to identify and report the true “beneficial owner” behind a legal entity involved in these types of real estate transactions.

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For more information about OnlineEd and their education for real estate brokers, principal brokers, property managers, and mortgage brokers, visit www.OnlineEd.com.

 All information contained in this posting is deemed correct as of the date of publication, but is not guaranteed by the author and may have been obtained by third-party sources. Due to the fluid nature of the subject matter, regulations, requirements and laws, prices and all other information may or may not be correct in the future and should be verified if cited, shared or otherwise republished.

The CFPB is the New Sheriff in Town … Ready for a Visit?

(OnlineEd – September 26, 2012) Compliance management requirements for all non-banks have reached a new level with the new Consumer Financial Protection Bureau (CFPB) Examination Manual. According to the CFPB’s Web site:

“The CFPB’s approach to non-bank examination will be the same as its approach to bank examination. It may include a combination of any of the following tools: requiring nonbanks to file certain reports, reviewing the materials the companies
actually use to offer those products and services, reviewing their compliance systems and procedures, and reviewing what they promised consumers. In general, we will notify a nonbank in advance of an upcoming examination.”

While the CFPB has not specified just how much notice they will provide prior to an exam, some non-bank companies have been warned of a CFPB audit up to three weeks in advance. That is an improvement over some state audit notifications, which are often no more than a couple of days. However, given the magnitude and uncertainty regarding what they will be looking for, three weeks seems hardly long enough to prepare. One comprehensive area of CFPB compliance review that is new to most non-banks is policies, procedures and training. It is important for all non-banks to pay attention to this new requirement, as non-compliance can have a pronounced negative effect on the outcome of the exam.

CFPB Examination Procedures

First, let’s review the purpose of the CFPB examination. The CFPB Supervision and Examination Manual is a guide demonstrating how the CFPB will supervise and examine consumer financial service providers under its jurisdiction for compliance with federal consumer financial law. Completing the examination modules allows examiners to develop a thorough understanding of mortgage loan originators’ and lenders’ practices and operations.

Understanding the Compliance Management Review

General Principles and Introduction

The CFPB refers to those under its supervision as “Supervised Entities.” Supervised entities within the scope of CFPB’s supervision and enforcement authority include both depository institutions and nondepository consumer financial services companies. According to the CFPB, the goal of the supervised entity is to maintain legal compliance. A supervised entity must develop and maintain a sound compliance management system that is integrated into the overall framework for product design, delivery and administration. Supervised entities are also expected to manage relationships with thirdparty service providers to ensure that these providers effectively manage compliance with federal consumer financial laws applicable to the product or service being provided. The CFPB expects every regulated entity under its supervision and enforcement authority to have an effective compliance management system adapted to its business strategy and operations. Each CFPB examination will include review and testing of components of the supervised entity’s compliance management system. The initial review will help determine the scope and intensity of an examination. The findings of more detailed reviews and transaction testing will determine the effectiveness of the compliance management system and whether enhancements or corrective actions are appropriate. Compliance may be managed on a firm or an enterprise-wide basis, and supervised entities may engage outside firms to assist with compliance management. However an entity chooses to manage compliance they are expected to comply with federal consumer financial laws and appropriately address and prevent violations of law and associated harms to consumers through its compliance management process. The CFPB expects that compliance management activities will be organized within a firm, legal entity, division, or business unit in the way that is most effective for the supervised entity.

What are the components of an effective compliance management system?

The CFPB advises in its Manual that “A sound compliance program is essential to the efficient and successful operation of the supervised entity, much as business plan.” A compliance program includes several components, two that many organizations are not prepared for include:

  • Policies & Procedures
  • Training

The CFPB outlines that a supervised entity should establish a formal, written compliance program. This program should be a planned and organized effort to guide the entity’s compliance activities. There should be a written program that represents an essential source document that may serve as a training and reference tool for employees. The CFPB cites that “A well-planned, implemented, and maintained compliance program will prevent or reduce regulatory violations, protect consumers from non-compliance and associated harms, and help align business strategies with outcomes.”

All non-banks must have a compliance program in place

The examination objectives and procedures for the compliance program of the supervised entity are outlined in the Manual. Below we will review two elements of the compliance program which include policies and procedures and training.

Policies and procedures – Examination objectives

The CFPB expects that compliance policies and procedures be documented and in sufficient detail to implement the boardapproved policy documents. Examiners will request and review compliance policies and procedures. They will discuss elements with compliance officers or other responsible officers and employees of the supervised entity. Here is a short list of what examiners will look for:

  • Request and review policies and procedures related to consumer compliance, including federal consumer financial laws and policies and procedures related to offering consumer financial products and services. 
  • Review policies and procedures to determine whether and how they address new or amended federal consumer financial laws and regulations since the preceding examination or since the most recent consumer compliance examination by a state or prudential regulator, if applicable, if this is CFPB’s first examination. 
  • Request and review policies and procedures to determine whether they cover consumer financial products or services introduced since the preceding examination or since the most recent consumer compliance examination by a state or prudential regulator, if applicable, if this is CFPB’s first examination. 
  • Review policies and procedures relating to compliance with specific regulatory requirements (such as the privacy of consumer financial information) and their implementing procedures. 
  • Review policies and procedures for products in which employee compensation structures, pricing or underwriting discretion, or other features may pose heightened risk of unlawful discrimination. 
  • Review policies and procedures designed to ensure that the entity’s third-party service providers comply with legal obligations applicable to the product or service of the examined entity and the provider. 
  • Review policies and procedures for record retention and destruction timeframes to ensure compliance with legal requirements.
  • If compliance procedures are embedded in automated tools or business unit procedures, determine that a qualified compliance officer or contractor reviewed these tools for consistency with policies and procedures and compliance with applicable federal consumer laws and approved them for the purpose for which they are utilized.
What examiners will be looking for in your training program:

The CFPB notes that education is essential to maintaining an effective compliance program. They note that all executives should receive sufficient information to enable them to understand the entity’s responsibilities and the commensurate resource requirements. Management and staff should receive specific, comprehensive training that reinforces and helps implement written policies and procedures. The company should also include requirements for compliance with federal consumer financial laws. This includes prohibitions against unlawful discrimination and unfair, deceptive and abusive acts and practices.

Examiners will be looking to see that the following is being met in a company’s training program:

  • Compliance training is current, complete, directed to appropriate individuals based on their roles, effective, and commensurate with the size of the entity and nature and risks to consumers presented by its activities. 
  • Training is consistent with policies and procedures and designed to reinforce those policies and procedures. 
  • Compliance professionals have access to training that is necessary to administer a compliance program that is appropriate for that supervised entity and its business strategy and operations.
Training – Examination procedures

Examiners will request and review training records and interview management and staff to evaluate this portion of the compliance program. Examiners will be looking to the following for training compliance:

  • Request and review the schedule, record of completion, and materials for recent compliance training of board members and executive officers. 
  • Determine the involvement of compliance officer(s) in selecting, reviewing, or delivering training content. 
  • Request and review policies, standards, schedules, and records of completion for compliance-specific training of compliance professionals, managers, and staff, and documents demonstrating that third-party service providers who have consumer contact or compliance responsibilities are appropriately trained. 
  • Request and review samples of the content of training materials and comprehension tests, including training related to new regulatory requirements, new products or channels of distribution, and marketing (including scripts). 
  • Request and review training developed as a result of management commitments to address monitoring, audit, or examination findings and recommendations or issues raised in consumer complaints and inquiries. 
  • Determine whether the program is designed to provide training about the specific regulatory requirements relevant to the functions of particular positions, such as the Truth-in-Lending Act (TILA) for loan officers, Fair Lending, Equal Credit Opportunity Act (ECOA), Home Mortgage Disclosure Act (HMDA), etc. 
  • Review records of follow-up, escalation, and enforcement for units with training completion rates that do not meet the supervised entity’s standards or deadlines. 
  • Request and review the supervised entity’s plans for additions, deletions, or modifications to compliance training over the next 12 months and any plans for changes to the overall training resources and compare actual training activities to prior plans. 
  • Draw preliminary conclusions about the strength, adequacy, or weakness of the training element of the compliance program, and select lines of business, organizational units, or other areas for more detailed review and testing.

This means that companies will need to have a complete and comprehensive training program in place that not only delivers training but also provides for the accountability to show Examiners content delivered in training programs, who attended and how often training is received.

What steps should you take NOW in order to prepare?
  1. Review and update your policies, procedures and compliance manual. If you do not have policies and procedures, get them now!
  2. Develop your training program for your staff. If you do not have a training program get signed up for one and make certain it provides your company with the ability to offer all the training you will need.
  3. Keep records of your training. This includes material, testing and tracking of all staff. This is more than just your Nationwide Mortgage Licensing System & Registry (NMLS) Continuing Education.
  4. Size is not important. You may be a one person Mortgage Broker, but in the eyes of the CFPB, you are a “Supervised Entity” and expected to abide by the rules, regulations and compliance requirements just like the “Big Banks.”

The Dodd-Frank Act, when fully implemented, will help to promote consumer education and financial literacy. The longterm goal is to provide education for home buyers entering into the housing market and protect them from loans that are not fair or would not be in their best interest. With an increased knowledge of the risks associated with financing the purchase or refinance of a residential property home buyers will be able to make more education decisions. The best advice in understanding, complying with and implementing the changes that we will be seeing in the coming years is to be ready. This is REALLY important. It is no longer what you say, but what your customers understand. The best way to succeed with the Consumer Financial Protection Bureau is to be proactive.

Free Anti-Money Laundering Compliance Handbook for AML, BSA, and SARs

OnlineEd

(OnlineEd® – InlineEd) – Are you confused by FinCEN’s new Anti-Money Laundering compliance requirements? Don’t be! OnlineEd® is providing a free guidebook that explains all the details of the required training ,  record keeping requirements, policies, and requirements for Compliance Officer registration.

Get Your PDF Version of the OnlineEd Anti-Money Laundering Compliance Handbook here.

Mortgage companies can develop their own training and compliance systems for AML, BSA, and SARs, but why not use ours? OnlineEd has developed a trouble-free system that can help you comply with these new requirements. OnlineEd’s® new InlineEd AML Compliance Bundle provides you with a well-written and customizable  anti-money laundering policy “template” that can be uses as your own company’s policy.  The bundle also provides a full AML compliance training course and integrated record-keeping for all of your employees. Check it out! It’s Free and there isn’t any obligation.

 Read More About the InlineEd AML Compliance Bundle

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For more about OnlineEd or the InlineEd compliance bundle, please visit www.OnlineEd.com or give us a call at 866.519.9597

How to Comply with Anti-Money Laundering Training Requirements

(OnlineEd®, InlineEd) – Residential mortgage lenders take note: The August 13, 2012 deadline for compliance with the new anti-money laundering (AML) and suspicious activity report (SAR) final rule is fast approaching.

In A Nutshell

This new expanded regulation applies to every single non-bank mortgage brokerage and mortgage lending company, regardless of size. The mandatory compliance deadline is August 13, 2012. By this date or sooner, you must:

  • Perform an AML risk assessment
  • Implement a written AML Program, including policies and procedures
  • Train employees on AML
  • Develop training program for ongoing AML training and tracking of new employees
  • Conduct and keep records of annual AML training

Would you like an all-in-one solution for this? Would you like it right now? OnlineEd® has developed InlineEd to meet your compliance needs!

“Instant-AML” Training

The instant-solution to your Anti-Money Laundering training needs is called InlineEd. The InlineEd AML Compliance Bundle is a 100% web-based solution comes with AML training, complete record keeping and reporting abilities, and has no installation or IT integration requirements. Just sign up and you’ve got this issue solved!

How It Works:

  1. Submit your information and payment through the checkout page.
  2. Send us a list of all of your employees.
  3. We upload your list and give you back login information that you can issue to employees.
  4. You also receive a pre-made Anti-Money Laundering “policy template” which you can customize and use as your company’s own policy if you don’t already have one.

Each employee will then have personal access to the AML training online. Employees can log in and complete the training at their convenience. When the training is completed, their records are recorded in the online database. You can pull up these records at any time in real time.

You can use InlineEd to train your current employees and keep using the system for future employees. Just enter their information into the system when they are hired and the AML requirements will automatically be applied.

Room To Grow With InlineEd

InlineEd handles policies, procedures, training, tracking, report, records, and compliance.

InlineEd can also help you with many other compliance needs:

  • Company and compliance training
  • NMLS continuing education
  • Education tracking, records, and reporting
  • Policies & procedures

Take A Tour!

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InlineEd(TM) is a software system developed by  OnlineEd® for mortgage broker and real estate lender continuing education and national compliance courses, as well as course compliance tracking software for employers.

For more information about InlineEd, please contact Paul Cleary at OnlineEd: (866) 519-9597 or visit www.onlineed.com/inlineed