In the December 9, 2010 Federal Register (75 FR 76677) the Financial Crimes Enforcement Network (FinCEN), a bureau of the Department of Treasury, issued proposed rules in a notice of proposed rule making (NPRM) that proposes to make non-bank residential mortgage lenders and originators (e.g., independent mortgage loan companies and mortgage brokers) subject to the anti-money laundering (AML) and suspicious activities reporting (SAR) requirements of the federal Bank Secrecy Act. If the proposed rules in the NPRM will affect your mortgage lending business, we urge you to submit comments to FinCEN. Written comments on the NPRM must be submitted on or before February 7, 2011. You may submit comments, identified by Regulatory Identification Number (RIN) 1506-AB02, by any of the following methods: • Federal E-rulemaking Portal: Follow the instructions for submitting comments. Include 1506-AB02 in the submission. Refer to Docket Number FINCEN-2010-0001. • Mail: FinCEN, P.O. Box 39, Vienna, VA 22183. Include 1506-AB02 in the body of the text. Please submit comments by one method only. Comments submitted in response to the NPRM will become a matter of public record. Therefore, you should submit only information that you wish to make publicly available. You may access the proposed rules and FinCEN’s comments at the following Web address:

Complete Memorandum