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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.