Manufactured Home Lenders Subject to New Anti-Money Laundering Rule

On February 7, the Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) released final rules extending anti-money laundering (AML) and suspicious activity report (SAR) requirements to non-bank residential mortgage lenders and originators.  Non-bank mortgage lenders will now be forced to assist law enforcement agencies with fraud detection just as larger financial institutions are required to do.

NOTE: the rule has not yet been officially published in the Federal Register, FinCEN has made a draft available here—statutes_regs/frn/pdf/1506-AB02_RMLO_Final_Rule.pdf.  The rule, which the agency began developing in 2009, will go into affect 60 days after publication in the Federal Register and compliance will be required within 180 days of publication.

Under the requirements, all non-bank lenders—including any entity making personal property loans for the purchase of manufactured housing (i.e., community owners that are engaging in lending activity and non-bank manufactured home lenders)—will have to, among other requirements, establish AML programs, designate a compliance officer, and develop training programs.

The regulations cover any residential mortgage lender, residential mortgage originator and loan or finance company (see pages 37-38 of rules for definition of terms and page 15 for commentary of those covered).

To help interpret the requirements of the new rule, the law firm Ballard-Sparh will be hosting an open webinar (AT NO COST) on Thursday, February 16 at 12:00 pm (Eastern Time). To register for the webinar, visit the Ballard-Spahr website at

For more information, go to or contact MHI Vice President of Government Relations Jason Boehlert at 703.558.0660 or

Jason Boehlert

Manufactured Housing Institute (MHI)

Vice President of Government Affairs

2111 Wilson Blvd., Suite 100

Arlington, VA 22201

Tel: 703.558.0660

Fax: 703.558.0401

2012 Legislative Conference & Business Meeting 
Crystal City, VA/ Washington, DC – February 26 – 28, 2012

 2012 Congress & Expo for Manufactured and Modular Housing 
Las Vegas, NV – April 10 – 12, 2012

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