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In Response To:
Thread Starter: Anonymous
Title: Re: Customer is a lender

Deposit only customer. They lend money to folks to purchase homes and collect payments and payoffs when the people refinance to other lenders. The customer mentioned that they only do this for people that are known or are referrals. What types of implications would there be with banking this customer. They are offering financial services to folks which would mean they are a non-bank financial institution. My other thought is that they need to have a BSA/AML program and designated compliance officer to administer the program and ensure employees are trained. Any other pitfalls with banking this type of customer?