The following is an outline of the scope of services, conducted either on-site or off-site, that Lenders Compliance Group, Inc. (“LCG”) provides in its auditing process:

  • Entrance Interview.
  • Audit responses to Prior Year Consulting and Regulatory Examination Reports, if applicable.
  • Issue and Review Document Request.
  • Conduct Anti-Money Laundering (AML) Risk Assessment.
  • Review:
  • AML Compliance Program Oversight.
  • Customer Identification Program Oversight.
  • Suspicious Activity Reporting (SAR) Policies and Procedures.
  • Suspicious Activity Monitoring Systems.
  • Transaction Testing, consisting of a sample of filed Suspicious Activity Reports (SARs) in order to determine completeness.
  • Information Sharing Practices under Section 314(a) and 314(b) of the USA PATRIOT Act.
  • Reporting of Cash Payments Over $10,000 (FinCEN Form 8300), if applicable.
  • Report of Foreign Bank and Financial Accounts (IRS Form TD F 90-22.1), if applicable.
  • Report of International Transportation of Currency or Monetary Instruments (FinCEN Form 105), if applicable.
  • Issue an Audit Report containing Findings and Recommendations.
  • Written and verbal (i.e., emails, telephone calls) communication between LCG and the Company on compliance administration matters, including but not be limited to, explanations of documents provided, clarifications of interpretations, and responses by LCG to Company questions or proposals.
  • Exit Interview.