Compliance

Mortgage CUSOs Must Develop BSA-AML Program

Those that offer residential mortgage services must comply with the rule by Aug. 13, 2012.

June 01, 2012
KEYWORDS bsa-aml , FinCEN , rule
/ PRINT / ShareShare / Text Size +

The Financial Crimes Enforcement Network (FinCEN) issued a final rule in February requiring “nonbank residential mortgage lenders and originators” (RMLOs) to develop an anti-money laundering (AML) program and report suspicious activities under the Bank Secrecy Act (BSA).

Credit union service organizations (CUSOs) that offer residential mortgage services must comply with the rule by Aug. 13, 2012. 

CUSOs that are RMLOs must develop a BSA-AML program that features:

► A designated BSA compliance officer to ensure the CUSO implements the program effectively;
 Internal policies, procedures, and controls based on the CUSO’s assessment of the money laundering and terrorist financing risks associated with its products and services;
 Ongoing training for individuals concerning their responsibilities under the program; and
 Independent testing to monitor and maintain an adequate BSA-AML program.      

The rule also would require CUSO-RMLOs to file suspicious activity reports with FinCEN. The rule doesn’t require RMLOs to comply with any other BSA reporting or recordkeeping regulations, such as filing currency transaction reports.

 Find more information at cuna.org/compliance and fincen.gov

Post a comment to this story

heroes

What's Popular

Popular Stories

Recent Discussion

Great article! Unfortunately, most employees don’t feel valued or appreciated by their supervisors or employers. In fact, research has shown that the predominant reason team members quit their jobs is because they don’t feel valued. This is in spite of the fact that employee recognition programs have proliferated in the workplace – over 90% of all organizations in the U.S. has some form of employee recognition activities in place. But most employee recognition programs are viewed with skepticism and cynicism – because they aren’t viewed as being genuine in their communication of appreciation. Getting the “employee of the month” award, receiving a certificate of recognition, or a “Way to go, team!” email just don’t get the job done. How do you communicate authentic appreciation? We have found people have different ways that they want to be shown appreciation, and if you don’t communicate in the language of appreciation important to them, you essentially “miss the mark”. Additionally, employees need to receive recognition more than once a year at their performance review. Otherwise, they view the praise as “going through the motions”. A third component of authentic appreciation is that the communication has to be about them personally – not the department, not their group, but something they did. Finally, they have to believe that you mean what you say. How you treat them has to match the words you use. If you are not sure how your team members want to be shown appreciation, the Motivating By Appreciation Inventory (www.appreciationatwork.com/assess) will identify the language of appreciation and specific actions preferred by each employee. You then can create a group profile for your team, so everyone knows how to encourage one another. Remember, employees want to know that they are valued for what they contribute to the success of the organization. And communicating authentic appreciation in the ways they desire it can make the difference between keeping your quality team members or having a negative work environment that everyone wants to leave. Paul White, Ph.D., is the co-author of The 5 Languages of Appreciation in the Workplace with Dr. Gary Chapman.

Your Say: Who should be Credit Union Magazine's 2014 CU Hero of the Year?

View Results Poll Archive