To detect and prevent money laundering
To prevent mortgage fraud
To alert borrowers that a SAR will be filed when criminal activity is susected
To allow banks and mortgage lenders to share information regarding criminal activity that borrowers are trying to keep secret
A business that involves a high volume of cash, such as a laundromat.
A system that allows money that was obtained illegally to be legally used ONLY IF the individual is purchasing a single family, owner occupied, residential property.
Taking illegal money and hiding it for several years until it becomes legal money.
Taking illegal or "dirty" money and placing it in the financial system in an effort to make the money look legitimate, or "clean."
AmeriFirst has developed and implemented internal policies, procedures, and controls.
AmeriFirst has designated a Compliance Officer responsible for ensuring that the AML Program is implemented effectively and updated as necessary.
AmeriFirst provides on-going training for all staff.
AmeriFirst conducts independent testing and monitoring to ensure compliance of the AML Program.
All of the above.
Loan Originators, processors, and servicing since they work directly with borrowers.
Everyone except loan officers; if a loan officer reports fraud such as a strawbuyer, the file might not close. Since this could adversly affect the loan officer's compensation, they are not required to report.
All AmeriFirst Financial Corporation employees.
Only branch managers, senior management, and servicing staff.
Borrower's name, social security number, income, property address, estimated property value, and loan amount.
Borrower's name, date of birth, address, and an unexpired government-issued form of identification with the borrower's photograph.
The borrower's name, date of birth, and identification number.
The borrower's fingerprints.
If another lender calls to transfer an FHA case #, we must tell them that we filed a SAR.
If a an attorney provides a subpoena to any employee, that employee must obtain and provide a copy of the SAR.
A SAR filing can be revealed to a borrower if, and only if, the borrower directly asks whether a SAR was filed. If the borrower doesn't ask, we can not provide a copy of the SAR.
All of the above
None of the above
Nothing unless you are absolutely certain that there is fraud.
Send an email to [email protected] with "Red Flag" in the subject line and the loan number, name of the borrower, and a summary of the red flags that exist in the body of the email. The compliance department will address the red flags and either resolve or escalate to the BSA Compliance Officer.
Fill out the red flags checklist and send an email to the BSA Compliance Officer at [email protected] for investigation.
Contact the borrower and let them know that AmeriFirst must complete a SAR since there are several red flags that exist in the file unless they can provide a valid explanation.