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Don DeRespinis
February 26, 2019

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

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...

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Debra Killian
February 14, 2022

The Feds Beef Up Employment Enforcement on Independent Contractors

With rates going up, refinance volume quickly heading south and originators looking for the next shiny thing, we are bound to see movement in the industry.  That means mergers, buyouts and some companies closing.  Migrating originators can be a tricky challenge for the next employer.  There are two issues...

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Don DeRespinis
December 17, 2018

CLOES.online Introduces Student Centric Interface

Now each student can select the format and user experience that works best for them.

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Debra Killian
May 27, 2022

UDAAP-ECOA-TILA Are You Ready for Examiners?

The overlap between federal and state laws and regulations becomes very apparent once there is an examination and/or an enforcement action. With COVID dominating our work environment over the past two years, not many audits or exams were scheduled by state regulators.  That is all about to change.  They...

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Debra Killian
March 18, 2025

What It Takes to Pass the NMLS Test!

If you are thinking of getting your Mortgage Loan Originator State License, there is a crucial statistic you need to know: the NMLS pass rate for first-time test-takers is hovering right in the mid-50s. To clarify, that means roughly half of everyone who sits for the exam fails on...

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Debra Killian
January 12, 2020

I am Supposed to Know All the Labor Laws?

So, now I am entrenched in all things Mortgage Businesses must know about employment. Everyday sipping my coffee, I read! Blogs, newsletters, announcements, court cases, compliance issues and a myriad of other topics for about an hour.  The topics range from mortgage compliance to IRS issues to mortgage fraud....

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Debra Killian
December 6, 2019

CIMBA LIVE 12/12/19 11:00am-12:00 pm. 1099 v. W-2

Connecticut Independent Mortgage Brokers Association offers live webinar. While a renewed interest in employee classifications started in Califorinia, it is spreading across the country. The recent California Dynamex Case codified the terms under which a “worker” can be classified as an independent contractor under the “ABC” Test (Assembly Bill...

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Debra Killian
March 27, 2019

FHA 4000.1 SF Housing Handbook Update

The FHA Single Family Handbook has been updated. Check out the complete list of changes. Some highlights include an update to the legal age for members of an LLC, an update to the standard to limit non-commission employees to those employees that perform underwriting or quality control activities, that...

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Debra Killian
October 25, 2023

Under 20 Employees? Your Business May Be Subject to New Beneficial Ownership Interest (BOI) Rules!

I usually write about mortgage or real estate professionals, but since I teach Anti-Money Laundering classes, I thought it would be helpful for all small businesses to know what’s coming. On September 18, 2023 the Financial Crimes Enforcement Network (FinCEN) published the final rules for the new Corporate Transparency...

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Debra Killian
August 13, 2019

Consumer’s Well-Being

Someone was kind enough to point out that my last post was shameful self-promotion. So let me approach this same topic a little differently. As an originator for over 25 years, it is very clear that we have a significant impact on the psychological emotional, and financial well-being of...

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What People Say

How real people felt about CLOES.online

Gedne Gosselin

The instructor was very knowledgeable and applied examples in every possible scenario, making the material easy to understand.

 

2018 CE Product

Student CE Class 2018

8 Hour SAFE Comprehensive Federal CE 2018 – November 2018

Deb was great in presenting the true nature of the course piece by piece and helped with her many years of experience outline some of the more critical areas of the industry and expectations. The course was excellent because the provider was an experienced mortgage veteran for many years and understands how to present the material to make sure the key points as well as the main facts of the true nature of the job are outlined while instilling the required knowledge of the federal laws and guidelines mandated in the industry.