Lender AML Program and Fund Source Attestation Forms
Lender AML Lookup and Certification Forms
Use these tools to check whether your lender has AML and SAR obligations under the Bank Secrecy Act. If the lender is covered by AML/KYC requirements, the loan will exempt the transaction from FinCEN real estate reporting because that lender is already reporting. Start with the lookup that matches your lender type below, and use the certification forms when you need a signed record for your closing file.
- Lender AML Lookup -
Is Your Lender AML/SAR Covered?
If the lender has an AML program and files SARs, the loan may make the transaction exempt from FinCEN real estate reporting. Pick the lookup that matches your lender type.
Banks & Savings Institutions
Confirms: FDIC-insured institution with AML/SAR obligations. These institutions always have AML/SAR programs. There is no need to look this up for major banks.
Credit Unions
Confirms: Federally insured credit union with AML/SAR obligations. These institutions always have AML/SAR programs. There is no need to look this up for major credit unions.
Mortgage Lenders & Brokers
Confirms: State-licensed mortgage lender/originator — generally AML/SAR covered since 2012
Hard Money, Private & Seller Financing
No government lookup available. These lenders may or may not have AML/SAR obligations.
Lender AML Program and SAR Obligation Certification
This one-page form lets a lender certify it is required to maintain an AML program and file Suspicious Activity Reports (SARs), which helps settlement agents determine whether the transaction qualifies as a “financed transfer” under FinCEN’s real estate reporting rule. The lender signs to confirm the certification is accurate and provides a compliance contact for any follow-up.
Hard Money Lender Wire Source Account Certification
This one-page form lets a hard money lender share the exact bank and fund source account information used to send loan wires, so the settlement agent can complete FinCEN Real Estate Report payment fields when a filing is required. The lender signs to confirm the information is accurate and understands the settlement agent may rely on it for FinCEN compliance to cover liability concerns.
