Comprehensive, integrated compliance solutions protecting RMLOs and Private Money Lenders from regulatory risks since 2012.
Get Started TodaySince 2012, SIRS has been a trusted partner for residential mortgage companies seeking to navigate the complexities of BSA AML/CFT compliance. We offer complete, integrated solutions—including ML/TF risk assessments, written policies, annual training, and independent testing—designed to ensure your firm remains secure, compliant, and focused on growth.
FinCEN regulation 31 CFR 1029.210(b)(1) requires that a mortgage company's BSA AML/CFT program be based upon an assessment of the money laundering and terrorist financing risks associated with its products and services.
Acting in partnership with Division One Compliance, LLC (D1C), SIRS will provide you with a money laundering/terrorist financing risk assessment. This assessment will include an evaluation of your products, services, customers, funding channels, and geographic locations to build a solid risk-based foundation for your entire compliance framework.
Under 31 CFR 1029.210(a), each loan or finance company must develop and implement a written anti-money laundering and countering the financing of terrorism program reasonably designed to prevent facilitation of illegal financial activities.
Distributed by SIRS and proprietary to Division One Compliance, LLC, our written BSA AML/CFT Compliance Program is clear, concise (typically less than 15 pages), indexed, and tailored to your specific business operations for effortless integration.
As mandated by 31 CFR 1029.210(b)(3), mortgage personnel must complete annual BSA AML/CFT training.
Prepared and owned by Division One Compliance, LLC (D1C)* and distributed by SIRS, this concise and engaging online course addresses real-world residential mortgage risks and regulatory requirements. Personnel can complete the course in about 15 minutes, and completion certificates are generated automatically for your recordkeeping.
FinCEN regulation 31 CFR 1029.210(b)(4) requires mortgage lenders and brokers to provide for independent testing of their BSA AML/CFT program.
Our testing process is collaborative and thorough. We review written policies, examine transactional records, assist in resolving identified gaps prior to test finalization, and deliver a detailed final audit report with practical recommendations. Most importantly, we will work with you to resolve any identified gaps before the test is finalized.
The testing process can typically be completed within 5 business days. Expedited (1-2 day) performance of the independent test can also be provided. Following the test, you will receive a detailed report with our findings and actionable recommendations to strengthen your program.
FinCEN identifies mortgage fraud as a primary risk. We provide the MFMLR form to seamlessly integrate into your loan origination process to systematically monitor and document red flags.
In addition to BSA AML/CFT compliance services, SIRS also offers Cybersecurity, Information Security, and FACTA Identity Theft Protection policies and procedures.
SIRS serves as your dedicated compliance partner year-round. We are available to answer regulatory questions, assist with examination prep, and help resolve operational issues.
We believe in clarity and trust. Our typical annual independent testing and BSA AML/CFT compliance packages for small to mid-sized firms are priced as follows:
SIRS acts as your dedicated consultant and independent testing auditor. To provide you with the most easily implementable compliance tools available, SIRS is an authorized distributor of proprietary BSA AML/CFT compliance products engineered by Division One Compliance, LLC.
Designing a mortgage risk assessment involves evaluating money laundering and terrorist financing vulnerabilities across your loan products (e.g., conventional, FHA, non-QM, private money), customer types, geographic locations, and origination channels. Under 31 CFR 1029.210(b)(1), this assessment forms the foundation of your BSA AML/CFT program. SIRS provides low-cost, expert risk assessment processes specifically tailored for RMLOs.
Yes. FinCEN regulations under 31 CFR Part 1029 define loan or finance companies to include non-bank residential mortgage lenders and originators, regardless of whether they utilize conventional funding or private capital. Private money lenders must maintain a written BSA AML/CFT program, conduct risk assessments, provide training, and undergo independent testing.
Independent testing involves reviewing your firm's written policies and procedures, examining loan files and SAR documentation to ensure operational compliance, evaluating compliance officer oversight, and verifying employee training records. SIRS delivers a comprehensive audit report detailing findings and actionable recommendations.
Our online training course is specifically designed for mortgage personnel and can be completed in about 15 minutes. It covers red flags, suspicious activity reporting, and industry-specific ML/TF risks. Upon completion, a certificate is issued automatically for compliance files.