Alert

Follow-Up: Anti-Money Laundering Program for Non-Bank Mortgage Lenders and Originators

August 5, 2009

To follow-up on the Client Alert we sent to you recently regarding FinCEN’s issuance of an advance notice of proposed rulemaking (“ANPRM”) relating to the application of anti-money laundering (“AML”) programs and suspicious activity report regulations to non-banking residential mortgage lenders and originators, we wish to inform you that the public comment for the ANPRM has now been established.  As a result of the publishing of the ANPRM in the Federal Register any comments you wish to make on the ANPRM must be received by FinCEN on or before August 20, 2009.  Please let us know if we can answer any questions you may have on the ANPRM or if we may assist you in preparation of any comments you may wish to submit.