Mortgage Investment Services Corporation 22316 Midland Drive • Shawnee, KS • 66226 • 913-390-1010 NMLS# 194708 • A Kansas licensed mortgage company #MC 0001182 Missouri Residential Mortgage Loan Broker Licence # 10-1912 Oklahome Mortgage Broker #MB001953 Colorado License #100044344 Nebraska Licensed Mortgage Company NMLS#194708 Arkansas Licensed Mortgage Company License #124530 20+ Years! Depend On Us! For 20+ years, community banks in the Midwest have depended on MISC’s expert mortgage services for their customers. • Free Loan Officer Training & Webinars •Offer all secondary market loan programs: VA, FHA, USDA/RD, Conventional & Jumbo •Earn more fee income with less risk Call or email today. Let’s discuss how MISC can help you! Andrew Holtgraves, Senior Vice President Cell: 913-558-2555 Email: Andrew@MISCHomeLoans.com Associate Member Violations & Penalties. The CTA makes it unlawful for any person to knowingly disclose or knowingly use BOI obtained by that person from a report submitted to, or an authorized disclosure made by, FinCEN unless such disclosure is authorized under the CTA. The CTA provides civil penalties in the amount of $500 for each day a violation continues or has not been remedied. Criminal penalties are a fine of not more than $250,000 or imprisonment for not more than five years, or both. The CTA also provides for enhanced criminal penalties, including a fine of up to $500,000, imprisonment of not more than 10 years, or both, if a person commits a violation while violating another law of the U.S. or as part of a pattern of any illegal activity involving more than $100,000 in a 12-month period. Violating applicable requirements could also lead to FinCEN suspending or debarring a requester from access to the beneficial ownership (BO) IT system. Under the Access Rule, “unauthorized use” includes any unauthorized access to BOI submitted to FinCEN, including any activity in which an employee, officer, director, contractor or agent of an authorized recipient knowingly violates applicable security and confidentiality requirements in connection with accessing such information. Rule Three/Revising Customer Due Diligence. FinCEN will next engage in a third rulemaking to revise FinCEN’s CDD Rule, consistent with the requirements of the CTA. The modification to the current CDD Rule is required to be published by Jan. 1, 2025. The Access Rule does not make any changes to FinCEN’s CDD Rule. FinCEN will develop compliance and guidance documents to assist reporting companies in complying with these rules. Some of these materials will be aimed directly at and made available to reporting companies themselves. FinCEN has already created the Introduction to Beneficial Ownership Information Reporting brochure and the Small Entity Compliance Guide. Both pieces of material can be found at fincen.gov/boi and can be provided to your customer as educational tools. Furthermore, FinCEN’s website will be updated regularly, and a call center is available by phone or email to assist businesses with additional questions. This article is for general information purposes only and is not to be considered as legal advice. This information was written by qualified, experienced professionals at FORVIS, but applying this information to your particular situation requires careful consideration of your specific facts and circumstances. Consult a professional at FORVIS or legal counsel before acting on any matter covered in this update. 17
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