[David] Let’s get over to you, Alice. Good to have you here with us and giving us an update on the legislative side of things. Anything happening.
[Alice] On the legislative update, I think as you mentioned Dave earlier, the MBA brought up that the CFPB repeat offender rule was rescinded. Yeah. Yeah. Don’t need to talk about a law no one has to pay attention to. Good news. We don’t have to do anything on that one. I think the writing was on the wall that was gonna go away, so hopefully lenders didn’t do too much for that one. What I do want to point out is this is an older final rule. It actually came out in August of 24 by FINCEN, the Financial Crimes Enforcement Network. And it was just recently given an extension. It was due to go into effect December 1st. And this FinCEN rule applies to a very unique segment of the market. So those of you who are in the lending business, all the controls you have to prevent against money laundering. And the A ML, what’s now referred to as the am ML. CFT countering financing of terrorism. And so versus B-S-A-A-M-L, which was, it was known as forever. With the SEN today, the, this new rule you can find it out within the federal register. And so we have an extension on this. This is, I say we, it’s not, we, it’s some of our listeners. This may apply to it is an unusual rule that’s going to require non-finance real estate transactions. So think about who that is, right? That’s potentially attorneys. I think realtors sometimes maybe dabble into, Hey, I’m gonna help you close this cash transaction. So there’s this waterfall that determines who would have to report. To Vincent that this transaction occurred. So we now have a rule out there, and again, it’s gonna be extended until March 1st. And it’s an example of, Hey, I decide I’m gonna go help a friend close a transaction, or buy a house for cash and help walk them through it. And you don’t know that you have laws you’re supposed to follow when you do that. So just a little. Heads up to our listeners. For those of you who might dabble in real estate transactions or know of others, this is an attempt by Vincent to try and scoop up some reporting. As it would relate to the types of transactions to report are gonna be the ones that are non-finance, but it’s when there is a trust involved, so you have a trust or a legal entity involved, you can find out more from your attorneys wiener, Brodsky and er of course does an amazing job. Yep. With. I’m sorry, I said that. No, I did say that. Wiener Brodsky. You did. You can find out more from them. You can also find out more about that just by reading. I can give Dave the link if you aren’t familiar with this, but I think it’s one of those things. Just a heads up. For those of you who aren’t our mortgage people listening all the time, we have other people outside the industry, a little related to the industry. You wanna get involved in a mortgage or real estate transaction. You better know that you have reporting requirements now. Two. Yes. So they can catch potential funding of terrorism activity Yep. Or other illegal business maneuverings with cash transactions in real estate.
[David] Yeah. There’s been money in laundering. There’s been a number of. Issues where the mortgage lending process opens the door for that because of the way we go about it. So it’s understandable why they’re doing it. Creates a little necessary evil that would feel I would call it as that. But anyway. Good. Good reporting. Thank you so much, Alice. Great stuff.
Alice Alvey, Master CMB
She handles development of their World Class Training program designed to support UHM partners and organizational effectiveness.
Prior to UHM, Alice served as Senior Vice President at Indecomm leading the Indecomm-Mortgage U division, Internal QA and Compliance and SaaS technologies. Indecomm acquired Mortgage U in 2013, where Alice was President/Co-founder, providing training and consulting since 1996. Prior to MU she served as SVP of Operations at a national bank overseeing operations for wholesale, retail and correspondent from underwriting through servicing, and compliance.
She has been in the trenches of mortgage lending operations from application through servicing for over 30 years. Her authoring work in training content, policies and procedures and the FHA/VA Practical guides illustrates her ability to bridge regulatory requirements with day-to-day operations.
Alice has been a weekly contributor to the Lykken on Lending show since its beginning in April 2009 and has made her weekly contributions to 450+ episodes!