Anti-Money Laundering Program Template
FinCEN has implemented a new initiative requiring the establishment of anti-money laundering (AML) programs for anyone that is considered a residential mortgage loan originator. On February 14, 2012, FinCEN published the “Anti-Money Laundering Program (AML) and Suspicious Activity Report (SAR) Filing Requirements for Residential Mortgage Lenders and Originators” Final Rule in the Federal Register. Non-bank companies that meet the definition of a residential mortgage lender and/or originator must comply with the rule by August 13, 2012.
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by George Allen, CPM, MHM
FTC Red Flags Rule
The Federal Trade Commission (FTC) has issued regulations requiring financial institutes to develop and implement written identity theft prevention programs as part of the Fair and Accurate Credit Transactions (FACT) Act of 2003. Programs must be in place by December 31, 2010. For detailed information on how this impacts manufactured home land-lease communities and retailers, click here.

The FTC has developed a template for businesses that are low-risk for identity theft. MHI has included suggested wording in the “Here are reasons we are at low risk for identity theft” section of the form. However, this form should be modified to fit individual business needs. The do-it-yourself template is available by clicking here

MHI has also developed a template that can assist businesses wanting to develop a more customized Red Flags program. It is available by clicking here.

Click here for the FTC guide, Fighting Fraud with the Red Flags Rule: A How-To-Guide for Business. On pages 19-21 you will find the common “Red Flags” that are part of Step 1 of the do-it-yourself template above which requires you to identify “Red Flags” that are relevant to your business.

Click here to view the FTC’s “Getting Red Flag Ready Video.”



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