Program Requirements
This federal law requires non-bank mortgage lenders to maintain an AML program and conduct independent testing.
What is the Bank Secrecy Act?
Large unexplained deposits and structured transactions are examples of these.
What are red flags?
This person acts on behalf of the true purchaser to conceal ownership or poor credit.
What is a straw buyer?
This government sanctions list must be checked before originating a loan.
What is the OFAC SDN list?
This person is responsible for overseeing Morgan Financial’s AML program.
Who is Rob Forsyth?
If a borrower receives large third-party funds without documentation, you should do this.
What is escalate to management and Rob Forsyth?
Fake pay stubs or fabricated employment verification fall into this type of fraud.
What is income fraud?
This report may be filed with FinCEN when suspicious activity is identified.
What is a Suspicious Activity Report (SAR)?
Independent AML testing must be conducted by someone who is not involved in this.
What is the day-to-day administration of the AML program?
This type of rapid resale at an inflated value with a manipulated appraisal is a common mortgage fraud scheme.
What is fraudulent flipping?
Cash-intensive businesses and unclear ownership structures require heightened scrutiny in this borrower category.
What is self-employment?
This rule prohibits disclosing to a borrower that a SAR has been filed.
What is the prohibition on tipping off (SAR confidentiality)?
This must occur at least annually and must include documentation of employee attendance.
What is AML training?
If you suspect suspicious activity, you must not do this.
What is confront or tip off the borrower?
A borrower who shows little knowledge of the property they are buying may indicate this scheme.
What is a straw buyer transaction?
Even though Morgan Financial does not process currency transactions, we are still required to do this.
What is detect and report suspicious activity?