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#2252855 - 04/23/21 03:01 PM RMLO and BSA
JackieW Offline
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Joined: May 2019
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Need some assistance with understanding RMLOs and BSA requirements. Are their specific sections of the BSA that apply to RMLO's such as an AML program, suspicious activity reporting, 314b, etc. but not others? Are they subject to 314a? If so, how would they register to receive lists? Any guidance on what does and doesn't apply to RMLOs would be helpful. I haven't been able to find much information that is clear on what specifically is applicable to them.

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#2252860 - 04/23/21 03:42 PM Re: RMLO and BSA JackieW
rlcarey Offline
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A Residential Mortgage Loan Officer?? Connected with a financial institution? I am having a hard time figuring out the context of your question.
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#2252861 - 04/23/21 03:45 PM Re: RMLO and BSA JackieW
ACBbank Offline
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Can you please confirm what an RMLO is?
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#2252941 - 04/26/21 02:51 PM Re: RMLO and BSA JackieW
CI@MBOC Offline
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Joined: Apr 2021
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I assume it's like an AMLO acronym......maybe Regional Money Laundering Officer? My experience with AMLO's is they are overseas form the US.

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#2253032 - 04/27/21 02:58 PM Re: RMLO and BSA JackieW
John Burnett Offline
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To the original poster. You may know what you mean by RMLO. Clearly, there are three people in this thread who would like to respond, but don't know what you mean by RMLO. Not all abbreviations or acronyms are universal. A quick search for BSA, for example yields wildly disparate results -- Boy Scouts of America, Birmingham Small Arms (they make "BSA" motorcycles), Bank Secrecy Act, and Bovine Serum Albumin. I'd lay odds that any mention of BSA in these forums would concern the Bank Secrecy Act, but RMLO is a puzzler.

Please decipher acronyms on first use in a thread.
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#2253034 - 04/27/21 03:09 PM Re: RMLO and BSA JackieW
John Burnett Offline
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Assuming that you are asking about a Residential Mortgage Loan Office, is it a loan production office for a bank? Not affiliated with a bank? Subject to a federal functional regulator, or not? Chartered under your state's banking laws and subject to that state's bank supervisory authorities?
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#2253070 - 04/27/21 06:47 PM Re: RMLO and BSA JackieW
JackieW Offline
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Joined: May 2019
Posts: 20
I apologize for the oversight in not explaining the acronym. My reference is to a Residential Mortgage Loan Originator, not affiliated with a bank, They are chartered under the state's banking laws and subject to the state bank's supervisory authorities.

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#2253073 - 04/27/21 07:12 PM Re: RMLO and BSA JackieW
rlcarey Offline
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I highly doubt that they are chartered. They are more likely licensed. But they would have to comply with:

https://www.law.cornell.edu/cfr/text/31/part-1029
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#2253201 - 04/29/21 01:37 PM Re: RMLO and BSA rlcarey
JackieW Offline
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Joined: May 2019
Posts: 20
Thanks rlcarey. I had previously reviewed the specific requirements you had mentioned which in some ways was a little confusing to me, hence my posted question. I find it hard to decipher in some parts what does/doesn't apply. In reading through the regs, it sounds to me like the wire transfer recordkeeping requirements apply to a loan/finance company and that they are also subject to receiving 314a requests. I was hoping that someone with a better understanding of those types of financial institutions could answer if I am correct that those sections apply.

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#2253216 - 04/29/21 05:02 PM Re: RMLO and BSA JackieW
rlcarey Offline
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Galveston, TX
Yup - CTRs and SARs too - basically the whole works
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