- 30 years of financial industry experience including AML compliance and training, securities firm operations and management
- 15 years of AML compliance advisory and education experience in the financial services industry
- Directed Securities Industry Institute at the Wharton School, University of Pennsylvania and other SIFMA training for member firms
- Faculty for Certified Compliance Regulatory Professional (CCRP) at Lubin School of Business, Pace University, ACAMS CAMS-Audit Certification, IMTC Compliance Certification Course, and ComplianceOnline
- Industry arbitrator for FINRA
- All 7 Best Practices
- Pre-Meeting Discovery Process
- One-on-One Call with Expert
- Meeting Summary Report
- Post-Meeting Engagement
Anti-Money Laundering - Non-Bank Residential Mortgage Lenders and Originators (RMLO)
- RMLOs may face difficulties in keeping up with ever-changing AML regulations.
Keeping up with regulations can be daunting. It's simply not enough to establish an AML compliance program and have a compliance officer manage it. No AML program can remain static. Understanding the risks inherent in your business is critical and the risk assessment is essential and must continue to be dynamic in order to keep up with AML regulations.
It is a regulatory expectation that the AML compliance program will be modified and updated to reflect regulatory updates and changes in the business of the firm.Yet, smaller RMLOs have smaller budgets and fewer resources and are often working with manual systems to manage these complex programs.
- RMLOs find it challenging to find an experienced and effective AML compliance officer.
Though it might seem obvious, when appointing a compliance officer, the individual must be competent in the area. He or she should have knowledge of the BSA and its implementing regulations and be qualified by experience, knowledge, and training.
Simply placing an existing compliance officer with no AML/BSA experience into this role may not be effective.
- Technology advancements and innovations have increased the scope and sophistication of criminal enterprise.
These changes have created the need for new regulations and risk mitigation efforts by institutions and organizations subject to AML. For example, online application processes, along with other recent innovations, present potential risks that require careful and thoughtful consideration. Applications that are not processed face-to-face provide a layer of anonymity and RMLOs are required to reasonably ensure they know the true identity of an applicant.
- RMLOs may have questions regarding AML record-keeping and information retention requirements.
The BSA establishes record-keeping requirements related to various types of records including: customer accounts (loans, for example), report filing requirements, and records that document a RMLO’s compliance with the AML program.
In general, most records must be maintained for at least five years. These records can be maintained in many forms, including original, microfilm, electronic, copy, or reproduction. A RMLO is not required to keep a separate system of records for each of the requirements; however, a RMLO must maintain all records in a way that makes them accessible in a reasonable period of time.