The Bank Secrecy Act authorizes the Treasury to issue regulations requiring financial institutions, including any “loan or finance company” to maintain records and to file reports that the Treasury determines to “have a high degree of usefulness in criminal, tax, or regulatory investigations or proceedings, or in the conduct of intelligence or counterintelligence activities, including analysis, to protect against international terrorism.”

In the supplementary information to the Final Rule, the term ‘loan or finance company’ “can reasonably be construed to extend to any business entity that makes loans to or finances purchases on behalf of consumers and businesses. Some loan and finance companies extend personal loans and loans secured by real estate, mortgages and deeds of trust, including home equity loans,” known as Residential Mortgage Lenders and Originators (RMLOs).

LENDERS COMPLIANCE GROUP, INC., an independent, external auditor, provides the review, program and testing requirements of FinCEN's Anti-Money Laundering Program for the Residential Mortgage Lender and Originator.