This notification is a Compliance Alert.

Please read through it in its entirety.

If you have not already made the appropriate arrangements to implement a test of your Anti-Money Laundering Program (AML), we urge you to take immediate action.

Contact us HERE!

Our schedule for the anti-money laundering audit is nearly full, though there are a few dates still available. After any open dates are taken, we will not schedule additional tests until October.

Testing annually is recommended. After the first audit - which should have been conducted by August 13, 2013 - and depending on those findings, it may be possible to implement an audit not later than eighteen months from the initial audit date. The frequency of subsequent audit periods is based on each prior period's findings. 

An audit of the procedures detailed in a non-bank's policy and procedures must be conducted either internally, in accordance with FinCEN guidelines, or, in accordance with FinCEN guidelines, by an independent, external auditor entirely independent of the BSA Officer and internal compliance staff.

The results of the audit must be reported to the audit committee of the Residential Mortgage Lender and Originator's (RMLO's) management and the BSA Officer. 

It is the responsibility of the BSA Officer to take appropriate action to correct any problems found as a result of the audit and promptly respond to the RMLO's audit committee.