AML And BSA Annual Risk Assessment Compliance

LL Logo 022015Here we are in late November, and there are some of you out there who need to have an independent party perform a Risk Assessment to satisfy state regulators regarding your compliance with Money Laundering Law and the Bank Secrecy Act.

We can do this for you, it will take about an hour and involves a small fee. $250 for survey and interview. The session will result in a complete Risk Assessment Report that will satisfy any requests for at least the next six months. This is an emerging trend. 

If you would like to schedule this, shoot me an email at nl@lockelaw.us  and let us know.

Nelson A. Locke, Esq.

Compliance Services USA

(800) 656-4584

Have you completed your 2018 your continuing education yet? You are running out of time.

We recommend Jim Montrym and Andrea Worthington of the Mortgage Broker School.

You can reach them at (800) 735-8565, or use their web site which is :

http://www.brokerschool.com/ :category/industry-partners-processing-compliance/ 

I have used their services personally for the last 15 years. Always good, never bad. Don’t wait until the last minute, space is limited. thw8s1030z

If you use them for your CE please tell us because it could be a helpful bit of information in the event you are audited.

Nelson A. Locke, Esq.

Compliance Services USA

(800) 656-4584

States where current Audit Activity is high.

 

Hello folks, here comes December!

Is your required annual training for AML and GLB done and certified? If not, give us a call.

In the past six weeks we have assisted in responding to at least 15 state or CFPB Audits.

We have successfully negotiated the lifting of three suspensions and successfully negotiated reduced fines for violations an average of 50%.

 

Audit satsifactoryIf you need that kind of Compliance Expertise in your corner,

email us at nl@lockelaw.us

Current Active Audit States

  • Florida

  • Texas

  • Washington

  • Oregon

  • North Carolina

  • Michigan

  • Virginia

  • New York

For more information, contact us at (800) 656-4584.

Nelson A. Locke, Esq

Compliance Services, USA

 

AML And BSA Annual Risk Assessment Compliance

LL Logo 022015Here we are in late November, and there are some of you out there who need to have an independent party perform a Risk Assessment to satisfy state regulators regarding your compliance with Money Laundering Law and the Bank Secrecy Act.

We can do this for you, it will take about an hour and involves a small fee. The session will result in a complete Risk Assessment Report that will satisfy any requests for at least the next six months. This is an emerging trend. 

If you are a small Broker shop, don’t be concerned. However, if you have multiple state licenses or more than 10 MLO staff, you may want to consider this extra step to stay in the safe zone.

If you would like to schedule this, shoot me an email at nl@lockelaw.us  and let us know.

Nelson A. Locke, Esq.

Compliance Services USA

(800) 656-4584

Florida OFR Audit Alert

August 12th, 2018

This is a special alert for my clients.

In the last ten days five clients have received audit letters from the OFR. All five clients had NOT been audited in 8 to 10 years. One had not been audited in 20 years.

It appears to me as if the OFR is on a “catch up” campaign. This means we know of three confirmed danger areas for an OFR audit.

  1. If you are a new company with a new NMLS number, you will be audited in the first 18-24 months. Perhaps, sooner. 

  2. If it has been at least 7 years since your last audit, get ready. Use the checklist in Compliance Book Three to see how prepared you feel. Then let me know.

  3. If you have had a consumer complaint that you failed to respond to, you can expect a visit. 

But the big shocker is you old timers. Many of you may have been feeling complacent. That is not good.

Let’s pull out the checklist and be sure you feel aware and prepared. 

We are now offering a two session “MOCK AUDIT” for companies who want to go the extra mile to be sure they are prepared. If you have interest, email me and let me know so we can get you scheduled.

There is a cost of $1,000 for this service. It will save you many times that much in potential fines. We have proof. 

That’s it for now.

Nelson A. Locke, Esq

Compliance Services USA

(800) 656-4584

ZILLOW Co-Marketing Program Survives

CFPB ends investigation of Zillow
By Richard J. Andreano, Jr. on June 28, 2018
Posted in CFPB Enforcement, CFPB Monitor, Mortgages
In a SEC filing dated June 22, 2018, Zillow Group announced that it is no longer under investigation by the CFPB for RESPA and UDAAP compliance with regard to its co-marketing program. Zillow Group had disclosed the existence of the investigation in May 2017.
According to the SEC filing, Zillow Group received a letter from the CFPB on June 22 stating that the CFPB “had completed its investigation, that it did not intend to take enforcement action, and that the Company was relieved from the document-retention obligations required by the Bureau’s investigation.”
The completion of the investigation leaves unanswered what concerns the CFPB may have had with Zillow Group’s co-marketing program, and whether the investigation was terminated because the concerns were addressed to the CFPB’s satisfaction or for other factors.

BE CAREFUL. JUST BECAUSE THE CFPB RELEASED ITS HOLD ON ZILLOW, IS NOT A TICKET FOR YOU TO INTO THE “GREY AREA”.

IF YOU ENTER INTO ANY KIND OF MSA, IT WOULD BE WISE TO ASK OUR ADVICE FIRST.

NELSON A. LOCKE, Esq,

(800) 656-4584

DODD FRANK REFORM BILL WEBINAR

Hi there.

The title says it all.

I will review the Dodd Frank Reform Bill as it affects Mortgage Brokers and Correspondent Lenders.

The webinar is free to subscribers, and will start promptly at 3:30 eastern time on Tuesday, June 26th.

To attend, go to https://global.gotomeeting.com/join/223553717

You can also dial in using your phone.
United States: +1 (646) 749-3122
Access Code: 223-553-717

I might have some attachments for you if time allows, but in any case we can have a good discussion about how the DF Reforms might (or might not) affect you and your business.

See you there.

 

Nelson A. Locke, Esq

Compliance Services USA

(800) 656-4584

http://www.expertlenderservices.com