An AML independent test built for mortgage lenders.
Non-bank residential mortgage lenders and originators must provide for independent testing of their anti-money laundering program. Garrett, McAuley & Co. tests your program against the rules that apply to mortgage companies, not a bank checklist, and tells you plainly where it stands.
- Advising lenders since
- 2003
- Mortgage companies served
- 600+
- Banks and thrifts served
- 120+
- Reviews a year
- 40 to 60
What we test
- Your written AML program, its approval, and the designated compliance officer
- Risk assessment and customer due diligence
- Suspicious activity detection, escalation, and SAR decisions, including well-documented decisions not to file
- OFAC screening and record keeping
- Information sharing requests (Section 314(a)) and other BSA reports that apply to your business
- Training, and oversight of any subservicer that handles your loans
- How your program covers the brokers and other agents you work with
What the rules require
Non-bank residential mortgage lenders and originators must maintain a written AML program with internal controls, a designated compliance officer, ongoing training, and independent testing.
The rule sets no fixed schedule. The scope and frequency of testing must match the risks of your products and services.
An outside firm or any officer or employee may do the testing, but not the AML compliance officer. The test must also check how your brokers and agents follow the program.
Lenders must also report suspicious activity and respond to FinCEN Section 314(a) information requests.
31 CFR 1029.320 (opens in a new tab) and 1029.520 (opens in a new tab)
These summaries are general information, not legal advice. See the cited rule for the full text.
How it works
- 1A 30-minute call about your channels, your program, and when your last test took place.
- 2One information request and one document upload, plus an interview with your compliance officer.
- 3Sample testing of the program in action, with a reviewer confirming every finding.
- 4A graded scorecard, findings, and a remediation plan, which we review with you before it is final.
Talk with us about what you need.
A 30-minute call is the fastest way to see whether we are a fit. No cost, no obligation.
What you receive
- A graded scorecard by area, from Strong to Deficient, with an overall rating
- Specific findings and a remediation plan with time frames
- A report you can hand to your board, warehouse lenders, and investors
Why Garrett, McAuley
- Built around the rules for non-bank mortgage lenders (31 CFR 1029)
- Light on your staff: one information request, one document upload, and one interview
- We test the program; we do not write it, so the test stays independent
Who you will work with
Joe Garrett
Co-Founder & Principal
Joe Garrett has worked in banking and mortgage banking since 1977, mostly in FDIC-insured and OCC-regulated banks. He served on the boards of four banking institutions and as Chairman and CEO of two of them.
LinkedIn
Michael D. McAuley
Co-Founder & Principal
Michael D. McAuley became a commercial banker in 1984, specializing in mortgage warehouse lending and commercial lending. He managed the warehouse lending business for Washington Mutual and JPMorgan Chase, and he has helped commercial banks set up, assess, and improve their warehouse lending operations.
LinkedIn
Steve Stone
Managing Director
Steve Stone has spent his career in independent mortgage banking, as an entrepreneur and as a senior operating executive. He founded and later sold an independent mortgage banking company, and he has managed loan production, servicing, secondary marketing, MSR strategy, and technology.
LinkedIn
Common questions
- Is an independent test required for mortgage companies?
- Yes. FinCEN requires non-bank residential mortgage lenders and originators to maintain an AML program that includes independent testing.
- Our company has never filed a SAR. Is that a problem?
- Not by itself. Many independent mortgage bankers file few or none. The test looks at whether you can detect and escalate suspicious activity and whether you document each decision.
- Can we combine this with an internal audit?
- Yes. Many clients add the AML test to an internal audit engagement so one visit covers both.
- How long does the test take?
- Most tests take a few weeks from the information request to the final report. The interview takes about 90 minutes of your compliance officer's time.
- Do you write AML programs?
- No. We test programs. Writing the program we test would compromise our independence, so we can refer you to firms that do that work.