Since 2012, SIRS has been a trusted partner for residential mortgage companies seeking to navigate the complexities of BSA/AML compliance. We’re more than just a service provider; we offer a complete, integrated solution designed to protect your business from regulatory risks and penalties. Our services, which include risk assessments, training, written policies and procedures, and independent testing, are built to ensure your business remains compliant, secure, and focused on growth.
FinCEN regulation 31 CFR 1029.210(b)(1) states that a mortgage company’s AML program must be based upon the firm’s assessment of the money laundering risks associated with its products and services—the risk assessment is the foundation upon which the AML program is built.
SIRS will conduct and document this assessment. In it, we will identify the money laundering and terrorist financing (ML/TF) risks found in the residential mortgage industry. We will then evaluate your products, services, customers, and geographic locations in the context of these risks. The result will be a personalized assessment which will serve as the basis of your BSA/AML compliance program.
31 CFR 1029.210(a) contains the following requirement:
“Each loan or finance company shall develop and implement a written anti-money laundering program that is reasonably designed to prevent the loan or finance company from being used to facilitate money laundering or the financing of terrorist activities.”
The AML Program comprises a comprehensive set of internal policies, procedures, and controls designed to ensure compliance with AML/CFT regulations applicable to the residential mortgage industry. Our mortgage industry AML Program is clear, concise (typically less than 15 pages), and designed for easy integration into your existing business operations. The written program will be personalized and tailored to your business activities. Designed to be a useful resource, the AML Program will include an index and easy-to-understand text.
As required by 31 CFR 1029.210(b)(3), ongoing training is a key part of a mortgage broker or lender’s AML program. A mortgage company should ensure that its personnel complete an AML/CFT training course each year.
Our mortgage industry AML/CFT training course is concise and engaging. Addressing relevant regulatory requirements and the risks found in the residential mortgage industry, the course can be completed in just 12-14 minutes. Upon completion, a training certificate is awarded.
FinCEN regulation 31 CFR 1029.210(b)(4) requires each mortgage lender and broker to provide for the independent testing of its AML Program. The testing is performed to ensure the AML Program meets relevant BSA regulatory standards.
Our independent testing process is designed to be collaborative and thorough. We begin by reviewing your written policies and procedures, then we examine your records to verify that your program is being implemented effectively. Most importantly, we will work with you to resolve any identified gaps before the test is finalized.
The testing process can typically be completed within 5 business days. Expedited (1-2 day) performance of the independent test can also be provided. Following the test, you will receive a detailed report with our findings and actionable recommendations to strengthen your program.
Mortgage Fraud and Money Laundering Review Form
FinCEN has identified mortgage fraud as a primary risk in the mortgage industry. To mitigate this risk, SIRS provides a Mortgage Fraud and Money Laundering Review (MFMLR) form. This tool can be seamlessly integrated into your loan origination process to help you systematically monitor for and document potential signs of fraud.
Cybersecurity, Information Security, and Identity Theft Protection
In addition to BSA/AML compliance services, SIRS also offers Cybersecurity, Information Security, and FACTA Identity Theft Protection policies and procedures.
Beyond these core services, SIRS acts as your ongoing compliance consultant. We are available to answer questions, provide guidance on emerging regulatory issues, and help you navigate the complexities of BSA/AML compliance with confidence.
Our comprehensive BSA/AML compliance services are competitively priced to fit your business. Our typical prices for annual testing for small to mid-sized firms are
We’re here to answer your questions and help you address BSA/AML regulatory requirements.
Call us today at (801) 613-5388 or email us at info@sirsco.com
Product & Intellectual Property Attribution
To provide comprehensive BSA/AML solutions, SIRS partners with Division One Compliance, LLC.
Division One Compliance, LLC Products: The BSA AML/CFT Policy Manuals, ML/TF Risk Assessment templates, online BSA AML/CFT training courses, and the mortgage fraud and money laundering review forms are proprietary products owned by Division One Compliance, LLC.
SIRS Proprietary Services: The Independent AML/CFT Test and the resulting AML/CFT Test Report remain the sole and exclusive proprietary property of Securities Industry Records Services, LLC (SIRS).