FinCEN Issues Reminder Regarding New AML Compliance Obligations for Non-Bank Residential Mortgage Lenders and Originators


On August 13, FinCEN reminded non-bank residential mortgage lenders and originators (RMLOs) that their obligation to comply with new anti-money laundering (AML) regulations started this week. In February, FinCEN finalized a rule to extend to RMLOs certain AML regulations already applicable to other types of financial institutions, requiring non-bank RMLOs to establish AML compliance programs and file suspicious activity reports (SARs). The rule took effect April 16, 2012, but non-bank RMLOs had until August 13, 2012 to comply. This week’s announcement provides references to relevant FinCEN publications to assist with compliance and reminds covered companies that all FinCEN reports must be filed electronically. For additional information and compliance tips, please check out BuckleySandler’s three-part Spotlight Series on these new requirements for non-bank RMLOs.


Published In: Administrative Agency Updates, Criminal Law Updates, Finance & Banking Updates

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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