Cost-effective, easily implementable compliance tools designed to fully address BSA AML/CFT regulatory requirements governing the residential mortgage industry.
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Residential Mortgage Lenders and Originators face unique regulatory scrutiny under Bank Secrecy Act (BSA) regulations (31 CFR 1029.210). When it issued its Final Rule in 2012, FinCEN explained that its purpose in applying anti-money laundering regulations to the mortgage industry had nothing to do with cash deposits.
Rather, the government needed the help of mortgage industry participants to inform the government about the prevalence of mortgage fraud. For this explicit purpose (detecting and reporting mortgage fraud), FinCEN enacted § 1029.210, Anti-money laundering programs for loan or finance companies.
Division One Compliance (D1C) delivers compliance products designed specifically for mortgage lenders and brokers. Refined and proven in the mortgage industry since 2012, our precision tools establish the exact risk-based framework state and federal regulators demand without creating unnecessary administrative burden for your business.
A risk assessment is the foundation of a compliance program. FinCEN has explained that mortgage fraud is the risk which must be addressed by an RMLO’s AML/CFT program. FinCEN has also given excellent guidance about the red flag indicators and the various types of mortgage fraud that may be encountered by a broker or lender. D1C’s risk assessment process incorporates FinCEN guidance and applies it to your firm’s business activities to produce a risk assessment that will meaningfully guide your compliance efforts.
Concise and meaningful compliance policies, procedures, and internal controls designed to guide your daily operations and satisfy regulatory scrutiny. Our written programs directly incorporate the required BSA pillars while remaining simple to navigate and execute.
Generic AML training fails to address mortgage industry concerns (mortgage fraud). D1C provides online training designed explicitly for mortgage lenders and brokers and their personnel. Staff can complete our targeted modules online in about 15 minutes.
An effective BSA AML/CFT program requires periodic independent testing. D1C partners with SIRS AML Compliance Services, our provider of choice and premier partner for independent testing services.
When state regulators, warehouse banks, or secondary market investors require an independent audit of your AML/CFT program, SIRS delivers a collaborative, thorough review and actionable audit report to demonstrate complete regulatory compliance.
Learn More About SIRS Independent Testing Services for RMLOs →State Examinations & BSA/AML Compliance
Answer: A state examination finding requires immediate, specialized action. To resolve the finding, you must implement a formal AML/CFT Risk Assessment process tailored specifically to Residential Mortgage Lenders and Originators (RMLOs). Division One Compliance (D1C) specializes exclusively in NBFI compliance. We quickly build a custom risk assessment that evaluates your specific loan products, customer profiles, geographic operations, and distribution channels. Coupled with our concise AML/CFT Policy Manual, D1C provides the exact documentation state examiners demand to clear your finding without operational disruption.
Answer: State examiners and FinCEN require a risk-based BSA/AML program built on key foundational pillars: a comprehensive business risk assessment, written policies and procedures, designated compliance management, ongoing employee training, and periodic independent testing. D1C provides a complete, easily implementable program designed specifically for mortgage brokers. Through our partnership with SIRS AML Compliance Services (www.sirsco.com), we also deliver independent testing services to ensure your program meets every state and federal standard.
Answer: Generic AML training focuses on traditional banking or cash transactions, which fail to address mortgage-specific red flags like loan fraud, synthetic identity theft, or straw buyer schemes. FinCEN and state regulators require training tailored to your actual business activities. D1C provides concise, role-specific AML/CFT training modules designed explicitly for mortgage loan originators and processing staff, ensuring your team knows how to identify and report industry-specific risks.
Answer: D1C specializes in rapid, cost-effective turnarounds for time-sensitive examination responses. Because we focus exclusively on non-bank financial institutions like RMLOs, we do not waste time with generic templates or lengthy onboarding. D1C delivers customized risk assessments, tailored compliance policy manuals, and online training modules rapidly, allowing you to submit a complete remediation package to your state examiner well within required response deadlines.
Answer: Yes. In partnership with SIRS AML Compliance Services (www.sirsco.com), D1C offers comprehensive independent testing of your AML/CFT program. If state examiners require proof of an independent audit, SIRS conducts a thorough, collaborative review of your written program and operational records, delivering a clear audit report with actionable recommendations to demonstrate full compliance to regulators.
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