- 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)
- 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.
- Regulatory changes continue and RMLOs must be prepared to meet the changes.
A number of regulatory changes and modification of existing rules – whether from FinCEN, OFAC, CFPB or others – require close attention. Fine-tuning of systems, training and other compliance program elements is essential.
- Reliance on third parties for any AML processes requires close scrutiny.
RMLOs often use the services of third-party providers to conduct certain aspects of processing, such as credit or background checks. Some third-party providers have AML capabilities such as OFAC screening. If your RMLO relies on suppliers to perform any AML processes, whether verification of identity or OFAC screening, check your service agreement to ensure that responsibilities are clearly described. Reliance must be clearly stated in the AML compliance policies and the compliance manager or designee should provide periodic oversight over the process.
- Regulators expect compliance officers to have competency in managing AML compliance.
RMLOs have been required to comply with AML regulations since August 2012. So most RMLOs have compliance programs up and running and are tracking unusual activity, providing training and performing independent testing. Regulators expect compliance officers to demonstrate competency in managing all the moving parts. Compliance officers who need additional training might consider taking more specific AML training. There are industry associations that provide supporting information for RMLOs and opportunities to network with other RMLOs. We are also seeing more RMLOs attending industry conferences and training events to learn best practices in AML.
- RMLOs are understanding that identity theft and mortgage fraud go hand-in-hand with money laundering.
Now that RMLOs have established AML programs, they see a clearer picture of where mortgage fraud might occur. RMLOs must be aware of persons presenting fake identities, doctored employment documents and other inflated proof-of-income documentation. In combination with discrete background and credit checks, RMLOs can separate legitimate prospects from fraudsters, and can use suspicious activity reporting to report the frauds. Read more about mortgage fraud and suspicious activity reporting at http://www.fincen.gov/financial_institutions/lfc/.