As a quick reminder, the Department of the Treasury’s Financial Crimes Enforcement Network finalized and implemented a rule in 2012, which defines non-bank residential mortgage lenders and originators as loan and finance companies. The designation requires these firms to establish anti-money laundering programs.

As a result, the firms should undergo an audit that will test it for compliance with relevant regulatory requirements. Per Rob Chrisman’s report:  

The scope and frequency of the testing is commensurate with the risks posed by the company’s products and services, though most firms elect to be audited annually. An officer or employee may conduct the audit if he or she is independent from the firm’s compliance department; otherwise a competent third party must conduct the audit.