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Debra Killian

MLO Licensing to Mastery – Your 1st Year

February 15, 2024

The definition of insanity: doing the same things over and over and expecting different results. Welcome to the mortgage business! Mortgage company owners and recruiters often entice new Mortgage Loan Originators (MLOs) into the industry with the allure of minimal entry requirements. However, this approach frequently leads to a puzzling outcome: these new entrants struggle to succeed. The critical question arises: where is the emphasis on truly understanding the mortgage business? Beyond the basics of …

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Debra Killian

Is Anti-Money Laundering (AML) Mandatory Compliance Coming for Realtors?

July 17, 2023

Do you know how money is actually laundered through real estate transactions?  Do you know your Anti-Money Laundering (AML) Training Requirements? Between 2015 and 2020, at least $2.3 billion was laundered through US real estate, with estimates by Washington, D.C. think tank Global Financial Integrity (GFI),  putting the number much higher. The real estate sector is now coming under increased scrutiny from government regulators and enforcement agencies for its compliance with anti-money laundering and reporting …

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Debra Killian

Mortgage Company Compliance Requirements for AML Training

July 11, 2022

How does a mortgage company meet the statutory requirement for Anti-Money Laundering education? The question comes up because many companies do not comply with the annual education requirement for all employees. In our opinion the law and regulations on AML training is purposely not specific because the term education is defined by the outcome and not the input. More simply put if you understand the requirements of the law you are educated. To be sure …

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Debra Killian

CLOES.online – On Demand BSA/AML Training

October 13, 2021

Real estate transactions are the easiest way to launder money due to the size of the transactions and the amount of money that can be “cleaned”.  All financial institutions are required to comply with the Bank Secrecy Act. Money laundering may also involve tax fraud as well as other potential crimes. All “financial institutions” must comply. According to the Bank Secrecy Act, a  “financial institution” includes an exhaustive list of entities, including but not limited to: …

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Debra Killian

Are Customers “Cleaning” Their Money In Your Transaction?

October 28, 2020

Money laundering is a huge problem for financial institutions and monitoring compliance and reporting is a challenge.  As I read through FinCEN’s recent announcement, it became clear…the law is not really clear!  Because real estate transactions are large in dollars, they are one of the easiest places to “clean up the money.” If you think Anti-Money Laundering regulations are vague or too complicated, now is your chance to help clarify how current regulations may be …

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Don DeRespinis

CLOES.online AML Program answers FinCEN challenge for Innovative Approach to AML Compliance – Expanding Requirements Under the CDD Rule and Mortgage Originators

February 26, 2019

FINRA Regulatory Notice 18-19 issued May 11, 2018 expands AML Program requirements to include additional risk-based procedures, or the “fifth pillar” required for AML programs under the new FinCEN CDD Ruling Since all AML programs are customized based upon the size and risk of a Mortgage Lender, Broker or Individual Licensee, the application of the “fifth” pillar must be factored into all programs beginning on May, 11, 2018. Therefore all AML programs must be modified …

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