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    • CLOES.online – On Demand BSA/AML Training

    CLOES.online – On Demand BSA/AML Training

    • Posted by Debra Killian
    • Categories AML, Banks, Compliance, Mortgage Competencies, Originators, Originators, Processors, Underwriters
    • Date 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: insured banks of the FDIC; commercial banks; trust companies, private bankers; an agency or branch of a foreign bank in the U.S.; credit unions; thrift institutions; SEC broker or dealers, insurance companies; loan or finance companies; licensed senders of money; other persons who engage in the transmission of funds, including any person who engages as a business in an informal money transfer system; any network of people engaging as a business in facilitating the transfer of money domestically or internationally outside of the conventional financial institutions system; persons involved in real estate closings and settlements; any other business designated by the Secretary whose cash transactions have a high degree of usefulness in criminal, tax, or regulatory matters.

    § 1020.210  Anti-money laundering program requirements for financial institutions regulated only by a Federal functional regulator, including banks, savings associations, and credit unions.

    A financial institution regulated by a Federal functional regulator that is not subject to the regulations of a self-regulatory organization shall be deemed to satisfy the requirements of 31 U.S.C. 5318(h)(1) if the financial institution implements and maintains an anti-money laundering program that:

    (a)  Complies with the requirements of §§ 1010.610 and 1010.620 of this chapter;

    (b)  Includes, at a minimum:

    (1)  A system of internal controls to assure ongoing compliance;

    (2)  Independent testing for compliance to be conducted by bank personnel or by an outside party;

    (3)  Designation of an individual or individuals responsible for coordinating and monitoring day-to-day compliance;

    (4)  Training for appropriate personnel; and

    (5)  Appropriate risk-based procedures for conducting ongoing customer due diligence, to include, but not be limited to:

    (i)  Understanding the nature and purpose of customer relationships for the purpose of developing a customer risk profile; and

    (ii)  Conducting ongoing monitoring to identify and report suspicious transactions and, on a risk basis, to maintain and update customer information.

    (c)  Complies with the regulation of its Federal functional regulator governing such programs.

    To satisfy your education requirement take a look at our on demand, video episode for your BSA/AML course.

    For questions or comments, email: deb@cloes.online.

    • Share:
    Debra Killian

    Debra Killian is a NMLS State Licensed Mortgage Loan Originator and Certified Residential Mortgage Specialist (CRMS), graduated from Western Connecticut State University, Danbury, CT with a B.B.A. in Accounting.

    She has over 35 years of financial, banking, accounting and business experience. Since 1994 when she started originating retail residential mortgages she has directly overseen and managed in excess of $1 billion in closed residential real estate loans, representing thousands of customers.
    Debra's experience and educational focus has given her an edge in the marketplace and a strong foundation as a passionate trainer for mortgage originators and Realtors offering customized sales and and mortgage-related training courses.

    She utilizes a proprietary software system (LoanMgr) developed by her partner and husband Don DeRespinis, CPA, CRMS designed for compliance, transparency and constant communications with customers, clients, Realtors, attorneys and closing agents throughout each and every transaction.

    In 2010, Debra co-authored one of the first NMLS approved 20-hour Pre-licensing SAFE Act courses, required for all state-licensed mortgage originators by Title V of the SAFE Act. She also develops for continuing education classes for Realtors.

    In 2011, Debra and Don co-authored The Mortgage Professional, National Residential Mortgage Loan Originator which has been approved by the NMLS for the 20-hour pre-licensing course.

    In 2014, she co-authored the MBA's School of Loan Origination(SOLO) I and II.

    Past positions include Directors of the CT Mortgage Bankers Association (CMBA) and National Association of Mortgage Professionals (NAMB), Past President of the CT Mortgage Association (CMA) as well as served on the Education, FHA and Government Affairs committees of NAMB. Debra is one of only four originators in CT to earn the Certified Residential Mortgage Specialist (CRMS) designation and the first originator in CT to earn the Lending Integrity Seal of Approval from NAMB.

    Debra speaks on a variety of topics to various professional groups and trade organizations and is available for custom course development and delivery.

    She is a member of the NAMB, CMA, AIME, Northern Fairfield County Association of Realtors (NFCAR), Connecticut Association of Realtors (C.A.R) and the National Association of Realtors. (NAR).

    Previous post

    Real Estate Update May 2021
    October 13, 2021

    Next post

    Redesigned URLA Video - How to Use the 2021 Loan Application
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