Cognitive Options Group Launches BSA/AML Training Curriculum for Non-bank Lenders to Meet the Requirements of Mortgage Industry Regulations

Lakewood, CO, February 26, 2015 --( Cognitive Options Group, a national consulting firm specializing in Mortgage Due Diligence and Compliance Reviews based in Lakewood, Colorado has announced that they now provide an online training solution to the financial services industry. The training is designed to help non-bank residential mortgage lenders and originators (RMLOs) comply with the rules issued by the US Treasury Department’s Financial Crimes Enforcement Network (FinCEN), requiring RMLOs to establish anti-money laundering (AML) programs and file suspicious activity reports (SARs).

The industry continues to see historic low interest rates in early 2015 and the need for proper management of AML/SAR’s policy and procedure is critical. With this expansion of volume comes increased regulatory risk and originators must be vigilant in meeting new regulatory and investor rules.

“As regulatory compliance for real estate financing has become more complex, the need for lenders and management to understand the volatile rule making environment is critical,” said Michael S. Richardson, Managing Director of Cognitive Options Group, LLC. “Growing fiduciary responsibility for all mortgage related leadership increases the need to engage mortgage industry experts for guidance.”

Cognitive Options Group’s comprehensive BSA/AML training program is tailored to help RMLOs meet the FinCEN requirements. The on-going employee training program was written by Cognitive Options Group’s Managing Director, Michael S. Richardson, “Author of An American Epidemic, Mortgage Fraud a Serious Business."

The objective of this training curriculum is:

· To provide an understanding of money laundering and how it can impact an organization
· To provide an understanding of loan fraud
· To provide an understanding of statutory and regulatory issues
· To understand the required components of an AML program
· To recognize the high risk customer
· To review customer due diligence
· To recognize red flags signifying unusual or suspicious activity
· To understand reporting and record keeping requirements under the Bank Secrecy Act

“With our experienced consulting team, comprehensive due diligence and compliance services and as a leader in serving the financial services industry, we’re uniquely qualified to design and provide the training programs needed to meet our client’s requirements to be compliant,” said Richardson. “These continue to be important rules for RMLOs, and this training will assist our clients in meeting the annual requirements.”

For all RMLOs, use this as a reminder of your compliance obligations under FinCEN's regulations that testing annually is recommended, but not later than every eighteen months. An audit of the procedures detailed in a RMLOs policy and procedures must be conducted either internally, in accordance with FinCEN guidelines, or, in accordance with FinCEN guidelines, by an independent, external auditor entirely independent of the BSA Officer.

An important distinction of this regulation is that The Internal Revenue Service (‘‘IRS’’) is the delegated authority under this regulation, not the CFPB. The IRS will examine for compliance with FinCEN’s regulations those financial institutions that are not examined by a Federal functional regulator.

Failure to comply constitutes a violation of the BSA, exposing the company to civil and criminal penalties. The severity of the penalties depends on the specific circumstances. Civil penalties can include a fine of $25,000 per day from the date of mandatory compliance, August 13, 2012, and criminal penalties can include imprisonment for up to five years.

Cognitive Options Group’s proprietary software tools and review procedures can assist in avoiding heavy fines and reputational risk that could threaten an institution that does not fully comply, particularly if it is publicly learned that money laundering or terrorist financing was undetected due to weak monitoring and controls.

About Cognitive Options Group, LLC.

Cognitive Options Group is based in Lakewood, CO and utilizes proprietary software tools to help financial institutions determine if loans have been underwritten to risk tolerances, guideline and program requirements (Prime, Subprime, VA and FHA), and compliance with GSE, QM, federal, and state regulations. Cognitive Options Group also provides companies with operational, transactional, and professional compliance services. We provide entire or specific outsourcing of risk management for our clients’ regulatory compliance function and its requirements. We provide a complete regulatory compliance program that includes risk assessments comprised of program development, implementation, and administration. We can supplement our clients’ internal resources to discover, review and provide a Best Practices solutions to specific regulatory compliance issues. We serve as an independent assessor of mortgage compliance procedures, to identify challenges, and propose revisions to policy and procedures.

To facilitate our client’s success, we believe we must rigorously uphold our core values. We maintain these standards consistently so you can always trust that our teams are more than a collection of individual perspectives. They represent one mindset…that of Cognitive Options Group, LLC.

For more information on Cognitive Options Group, LLC please call (720-370-9090).
Cognitive Options Group LLC
Michael S Richardson