More Regulation for MH Lenders has learned from Jason Boehlert, vice president of government relations at the Manufactured Housing Institute (MHI), 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. Treasury began developing the rule in 2009. It will go into affect 60 days after publication in the Federal Register, and compliance will be mandatory 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

(Graphic credit: Manufactured Housing Institute)

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