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MBA Comments to FinCEN on Proposal to Expand Suspicious Activity Reports

WASHINGTON, D.C. – February 7, 2011 – (RealEstateRama) — On Friday, February 4, 2011, the Mortgage Bankers Association, (MBA) submitted the attached comment letter to the Financial Crimes Enforcement Network (FinCEN) in response to FinCEN’s proposal to expand its anti-money laundering programs to help reduce mortgage fraud against lenders through a Suspicious Activity Report (SAR) reporting requirement (Notice of Proposed Rulemaking 1506-AB02).

MBA is generally supportive of FinCEN’s proposed expansion of SAR reporting requirements to non-depository mortgage lenders and originators. In the letter, MBA’s President and CEO John A. Courson offers a handful of recommendations for FINCen, including improved means for lenders to report mortgage fraud on the SAR, to consider as it finalizes and implements the rule.


The Mortgage Bankers Association (MBA) is the national association representing the real estate finance industry, an industry that employs more than 280,000 people in virtually every community in the country. Headquartered in Washington, D.C., the association works to ensure the continued strength of the nation’s residential and commercial real estate markets; to expand homeownership and extend access to affordable housing to all Americans. MBA promotes fair and ethical lending practices and fosters professional excellence among real estate finance employees through a wide range of educational programs and a variety of publications. Its membership of over 2,200 companies includes all elements of real estate finance: mortgage companies, mortgage brokers, commercial banks, thrifts, Wall Street conduits, life insurance companies and others in the mortgage lending field. For additional information, visit MBA’s Web site: