Episode 9
Navigating FINTRAC Compliance in the Mortgage Sector
As the mortgage sector navigates new FINTRAC regulatory requirements, dive into unique insights from the ReallyTrusted team, with insights from Catagay Sen and Taylor Cameron. With the recent expansion of FINTRAC oversight to mortgage brokers, both professionals share critical observations on challenges faced by designated individuals and principal brokers in implementing compliance measures. Taylor’s experience speaking to new and potential clients’ sheds light on common misconceptions, while Catagay offers a deep dive into the evolving, policy-specific concerns mortgage brokerages encounter. Together, they discuss the ways ReallyTrusted is helping client’s approach FINTRAC compliance with clarity and confidence, helping ensure these new requirements are met effectively.
This episode offers an essential look at the early days of FINTRAC’s regulations in the mortgage sector, uncovering valuable insights for brokerages looking to stay compliant and prepared.
Key Takeaways:
- Many mortgage brokerages face challenges understanding their role under FINTRAC regulations.
- Designated individuals often need help crafting policies tailored to new compliance standards.
- Misunderstandings are common around what data must be recorded and reported.
- Brokerages frequently underestimate the time and resources required for full compliance.
- ReallyTrusted provides tailored programs to help brokerages meet compliance requirements efficiently.
Connect with Greg and Really Trusted at:
https://www.facebook.com/ReallyTrusted/
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#FINTRAC #MortgageCompliance #RealEstateCompliance #RegulatoryStandards #ReallyTrusted #ComplianceManagement #BrokerageCompliance #KnowYourCompliance #FINTRACExpress
Transcript
All right, welcome to another episode of The Know Your
Greg Dent:Compliance podcast. Thank you so much for joining us. Today. I'm
Greg Dent:going to be interviewing Cagatay Sen from the really trusted
Greg Dent:team. He's our FINTRAC Express program lead, and Taylor
Greg Dent:Cameron, who's our manager of business development. And the
Greg Dent:topic I wanted to bat around today is something that we
Greg Dent:actually are uniquely positioned to talk about, and that's
Greg Dent:specifically how things are going in the mortgage sector in
Greg Dent:the first three ish weeks now, depending on when you're
Greg Dent:listening to this of their quote coverage under the fin track,
Greg Dent:regs. So let me kind of give us give our audience a bit of
Greg Dent:framing here, Taylor spends most of her day most weeks, chatting
Greg Dent:with potential clients, people who have realized that they need
Greg Dent:to know more about FINTRAC. They reporting entities across both
Greg Dent:the real estate and the mortgage sectors primarily, and develops
Greg Dent:some interesting insights around their beliefs at that stage,
Greg Dent:chat. I spends most of his life chatting with brokerages who
Greg Dent:have chosen to hire us, and gets really granular on their fin
Greg Dent:track compliance policies. And so what I was hoping to bring to
Greg Dent:our audience today is the insights that Taylor and Chad I
Greg Dent:have brought or have gleaned through the last three Well,
Greg Dent:actually, we've been we launched this kind of mostly about a
Greg Dent:month ago. Now today's date is November 1, but we launched. So
Greg Dent:we launched this the big roughly the beginning of October, where
Greg Dent:we really started talking with a lot of brokerages specific
Greg Dent:around their policies. So with all of that long intro, let's
Greg Dent:get into it. Taylor, let's start with you. Can you give me three,
Greg Dent:four, maybe five, things that you've observed as the feedback
Greg Dent:that mortgage brokerages, the designated individuals,
Greg Dent:principal brokers, depending on how you want to call them, what
Greg Dent:they're seeing as the challenges in their fin track compliance
Greg Dent:programs?
Taylor Cameron:Yeah, that's interesting. I mean, I don't
Taylor Cameron:even know if we can say that they're seeing it, or rather,
Taylor Cameron:what I'm seeing, because I don't. I think we, I think we've
Taylor Cameron:got two populations. I think we've got the the population
Taylor Cameron:that doesn't know what they don't know. And then as as we're
Taylor Cameron:moving through this, we have the population that knows there's a
Taylor Cameron:lot they don't know. So I feel like some of the bigger things,
Taylor Cameron:I think, that I'm seeing just as a general as a whole, is that we
Taylor Cameron:have a lot of individual brokers going in and finding their own
Taylor Cameron:IDD software that works for them individually, and they're not
Taylor Cameron:referencing back to our Di's and our principal brokers to find
Taylor Cameron:out what is actually indicated as what we're using in our
Taylor Cameron:policy and procedure manuals. So that's a big piece. I feel like
Taylor Cameron:a lot of we've got a lot of designated individuals waiting
Taylor Cameron:for templates to come from associations. And, I mean, we
Taylor Cameron:can certainly dive into that topic a little more. Yeah, I
Taylor Cameron:think
Greg Dent:that's worth coming back to for sure. Yeah, yeah,
Greg Dent:yeah.
Taylor Cameron:What are some other things here? And I think
Taylor Cameron:the other common thread is that we are hearing, I'm a small
Taylor Cameron:brokerage. All of my clients are repeat. They're all low risk.
Taylor Cameron:I've dealt with them for years and or that I'm so small that,
Taylor Cameron:you know what I really, you know, I don't really need to do.
Taylor Cameron:This is another unique and interesting perspective in the
Taylor Cameron:industry. So, I mean, those are some of the things that come top
Taylor Cameron:of mind.
Greg Dent:Okay, so the overarching things I think are,
Greg Dent:are generally a lack of, perhaps frontline staff seeing IDV as
Greg Dent:being the entirety or the bulk of their obligations or and
Greg Dent:whether that's true or not, as a conversation we'll have in a
Greg Dent:second, but, but really being focused on that IDV part di is
Greg Dent:thinking that Maybe templates are going to solve this for
Greg Dent:them, and then going back to the frontline staff. Well, actually,
Greg Dent:this is kind of where frontline staff and Di's need to get on
Greg Dent:the same page. Is what is a low risk individual and what is risk
Greg Dent:and how is risk identified?
Taylor Cameron:Okay? And it's not a tech box determination,
Taylor Cameron:right? Yeah. Okay. Yeah, yeah,
Greg Dent:yeah, no, and we'll sorry. We'll come back to that.
Greg Dent:I want to open up the conversation to chat. I see what
Greg Dent:he's seeing on the other side, people who have chosen to engage
Greg Dent:with us for either of the two reasons Taylor has identified,
Greg Dent:maybe they know they have a problem, they need some help, or
Greg Dent:they don't know they have a problem, but they need some
Greg Dent:help. What are you seeing in those in those meetings, when
Greg Dent:you're doing that consult, when you're creating the policy
Greg Dent:manuals, where are you finding the the real challenges that the
Greg Dent:eyes and brokerages are facing?
Cagatay Sen:Right? Yes, so I've had several meetings now, and
Cagatay Sen:one of the issues. That I've seen pop up regularly is that
Cagatay Sen:these guys, up until now, have been used to having the lenders
Cagatay Sen:do all the pretty much, you know, burdensome work of ID
Cagatay Sen:verification, etc, ensuring that the proper controls were in
Cagatay Sen:place to properly identify the clients things like that, and
Cagatay Sen:they never touched based on any client funds, either. They see
Cagatay Sen:they do not do that. So one of the issues now that with the
Cagatay Sen:financial competition coming to play as of october 11, is that
Cagatay Sen:they are a bit nervous as to how they're going to go through this
Cagatay Sen:process, because they are the front line now to do this, I
Cagatay Sen:mean, the assurance that I try to give them naturally is that
Cagatay Sen:we as really trusted, are here to assist them along the way
Cagatay Sen:from our systems that are going to be in place for the ID
Cagatay Sen:verification, etc. And that's where Taylor, I agree with you,
Cagatay Sen:some have already started to, in the past, utilize some IDV third
Cagatay Sen:party applications, but I always assist them that you know you
Cagatay Sen:because the question pops up sometimes that they also asked
Cagatay Sen:whether they need another application for this purpose. I
Cagatay Sen:said you don't, because when you sign up for our program, you're
Cagatay Sen:getting full coverage as to the systematic capabilities of the
Cagatay Sen:app, etc. So all the ID verification, remote ID
Cagatay Sen:verification applications are going to be in place, and that's
Cagatay Sen:going to be covered in respect of your sanction is controlled,
Cagatay Sen:peppers, controls, etc. We're going to ensure that you know
Cagatay Sen:your database is going to be covered respect your high risk
Cagatay Sen:of monitoring obligations, your adverse media control, which
Cagatay Sen:will come into play, which, you know, really gives them a good
Cagatay Sen:insight into what we can do for them, etc. And the training
Cagatay Sen:aspect is very exciting for them, I see, especially they
Cagatay Sen:want to have this as soon as possible training, because they
Cagatay Sen:want to create that much shift in mindset for their
Cagatay Sen:underwriters, their you know, associates, etc. We're going to
Cagatay Sen:be dealing with the client information, the files, etc.
Cagatay Sen:They want to understand what those indicators are going to
Cagatay Sen:be. How do you risk great clients? Especially this is
Cagatay Sen:something that all. I also underline many times that it's
Cagatay Sen:okay to risking your clients as high as clients, because if you
Cagatay Sen:don't in the future, and you have a possible field track
Cagatay Sen:examination coming through, and they identify something, where
Cagatay Sen:you they go in the field that should have been read as a high
Cagatay Sen:risk client, then you're going to be in trouble. So I am going,
Cagatay Sen:I'm reiterating throughout these meetings that risk rating your
Cagatay Sen:clients is high risk is okay, and it's important for you. And
Cagatay Sen:I also give them the example that you know, there's some
Cagatay Sen:perception that if you risk a high risk client, then somehow
Cagatay Sen:regulator authorities are going to know about this, etc, and
Cagatay Sen:they're going to flag their clients and actually may pick,
Cagatay Sen:carry out further orders and things like that. Is not the
Cagatay Sen:case in terms, of course, but it is to ensure that, you know, you
Cagatay Sen:have the proper controls in place to keep that business
Cagatay Sen:relationship, you know, and under taps throughout that time.
Cagatay Sen:Yeah.
Greg Dent:No, that's interesting. So if I can unpack
Greg Dent:what, what I've just heard you say that I think was really
Greg Dent:interesting is kind of two pieces there. One, a lot of
Greg Dent:these mortgage entities were already aware of some of the
Greg Dent:anti money laundering stuff because of their upstream
Greg Dent:relationships, and had been relying on those upstream
Greg Dent:relationships. Well, relying is too strong word. Actually, just
Greg Dent:knew they could ignore that part of the world because of those
Greg Dent:upstream relationships, and they were right and there. But the
Greg Dent:result of that, and this is where I'm particularly
Greg Dent:interested to hear this, is they're now they realize they
Greg Dent:have these obligations. They're taking them very seriously.
Greg Dent:Their excitement around training is amazing and awesome, and so
Greg Dent:wonderful to see is very refreshing, in fact. But they
Greg Dent:they're not necessarily understanding all of the the
Greg Dent:specific part around this risk, risk rating clients, and that's
Greg Dent:something Taylor touched on as well. This this challenge that
Greg Dent:frontline staff in particular have around appropriately risk
Greg Dent:rating clients, and realizing that that's not a bad thing, and
Greg Dent:realizing that that's actually what you want, and and realizing
Greg Dent:that just because you know them doesn't mean they're low risk,
Greg Dent:which is something you know, we've been we've been struggling
Greg Dent:with as a company, with our with our real estate brokerages for
Greg Dent:years. In fact, it's not an uncommon conversation to be
Greg Dent:having. In fact, I had this conversation the beginning of
Greg Dent:this week when I was presenting one of our brokerage partners
Greg Dent:where that's exactly what the agent said, and I had to walk
Greg Dent:them through how the flaws in their thinking on that. So no,
Greg Dent:that's interesting, and really kind of appreciate the feedback
Greg Dent:on that. So let's pick through. Let's start at the beginning.
Greg Dent:There's kind of four or five areas there that I've heard
Greg Dent:everybody kind of talk about. So let's talk about this IDV thing.
Greg Dent:Taylor, you brought this up as as something that we're seeing
Greg Dent:kind of a fragmented use of IDV solutions is perhaps the
Greg Dent:language there and chat. I You brought this up as you know,
Greg Dent:what other programs are people going to have to use? So what's
Greg Dent:the like? I mean, obviously I know the answer to this, but I
Greg Dent:don't want to just battle on Chad. I What is your view?
Greg Dent:You're the you're the fin track program expert, you guys, you're
Greg Dent:the one doing the consults. Is it okay to be using various IDV
Greg Dent:solutions? Do? Is that what we want to encourage? We want to
Greg Dent:discourage that. What would your view be on that?
Cagatay Sen:Well, I mean, as really trusted, we're providing
Cagatay Sen:a, you know, turnkey solution in respect to the establishing the
Cagatay Sen:compliance program, and which is not necessarily just, you know,
Cagatay Sen:preparing the documentation and placing in a folder and handing
Cagatay Sen:it over to the client. We're ensuring that with the
Cagatay Sen:systematic tools in place as well. Hence the IDV solution
Cagatay Sen:which we're providing, we're giving a complete program and
Cagatay Sen:where they're able to utilize the app with the convenience of
Cagatay Sen:having available on their forms, etc, and ensuring that, you
Cagatay Sen:know, they trust us in the properly you know, carrying out
Cagatay Sen:those controls in the background for our systematic databases,
Cagatay Sen:and also the added the you know, comfort of carrying out the
Cagatay Sen:sanctions control Purpose controls. Which have we in place
Cagatay Sen:as well, etc. So I definitely underlie the message when I
Cagatay Sen:really think, when I received a question like this, is, you
Cagatay Sen:don't need any other solution. You might have done so in the
Cagatay Sen:past for any other purpose, just to have the completed some of
Cagatay Sen:your mortgage loan records. Perhaps, I don't know that would
Cagatay Sen:have been your own choice at that time, but as you're signing
Cagatay Sen:with really trusted and you're signing for the fin track
Cagatay Sen:Express program, you have to be trusting us and ensuring that
Cagatay Sen:you know we do the proper thing for you guys, which is the
Cagatay Sen:documentation, the training modules, the whole IRT app
Cagatay Sen:solution, which we provide and plus, on the other hand, for
Cagatay Sen:your high risk clients, the address media controls and
Cagatay Sen:monitoring tools that we provide for you in a monthly basis, etc.
Cagatay Sen:Plus, I also underlined the fact that, for example, in a possible
Cagatay Sen:future control examination when, if and when they receive such
Cagatay Sen:requests for information in the form of an E car, a podcast, a
Cagatay Sen:subject we covered in the past? Yeah, we are always here to
Cagatay Sen:assist them as well, so that they are assured that you know
Cagatay Sen:they're properly discussing those questions, so that Finch
Cagatay Sen:doesn't necessarily need to go into any further detail, or
Cagatay Sen:might actually leave it at that at that point.
Greg Dent:Yeah, so what I'm hearing you say, and I think I'm
Greg Dent:going to bring Taylor into this in a second, but what I'm
Greg Dent:hearing you say is that the the importance of having IDV is
Greg Dent:actually just a small part of that frontline staff, and the
Greg Dent:real kind of key about what we're offering is, in fact, the
Greg Dent:integration of all of the thinking into one platform in a
Greg Dent:meaningful way. Taylor, is that ringing true to the people
Greg Dent:you're talking with? Is that? Is that what you're hearing, what
Greg Dent:are the benefits that you're seeing that maybe chat I hasn't
Greg Dent:touched on and or what are the drawbacks to that approach? I
Greg Dent:suppose? Yeah, I
Taylor Cameron:think really important to talk about the
Taylor Cameron:drawbacks too. So I agree with everything that Chad has said,
Taylor Cameron:but one of the drawbacks in using multiple streams of an IDV
Taylor Cameron:is that, how are you then providing consistency in the way
Taylor Cameron:that we are doing risk determinations? If we're using
Taylor Cameron:two different programs, they might be, you know, the value
Taylor Cameron:systems might be different or off. So trying to get a
Taylor Cameron:continuity across those systems and then being able to document
Taylor Cameron:it, I think you're going to run into a big challenge when it
Taylor Cameron:comes to an audit and the questions that are going to be
Taylor Cameron:asked of you, and how these two different groups, if there's two
Taylor Cameron:different softwares, how these two different groups are aligned
Taylor Cameron:in doing those risk determinations. So I'd say
Taylor Cameron:that's a challenge. And again, I just think it comes back to
Taylor Cameron:education. I don't think that we are fully grasping yet in the
Taylor Cameron:mortgage industry, what FINTRAC is really about, and that there
Taylor Cameron:has to be a continuity across all of your pillars, that
Taylor Cameron:whatever you have done in terms of risk determinations is how
Taylor Cameron:and tied into, sorry, you want to, I can see, well, I
Greg Dent:just want to jump in, because you mentioned pillars,
Greg Dent:and I some of our pillars, and I some of our audience may or may
Greg Dent:not be familiar with the concept. So let's just unpack
Greg Dent:that for a second, if you would just just walk people through
Greg Dent:that the five what
Taylor Cameron:we call the five pillars. Yeah, so you know the
Taylor Cameron:five pillars and what a program should entail as a documented
Taylor Cameron:compliance officer, kind of easy, but there are some
Taylor Cameron:specific traits and skills that you. Going to want to see in the
Taylor Cameron:person that you put forward is that, because there has to be
Taylor Cameron:enough AML knowledge to be able to properly roll that out and a
Taylor Cameron:few other things. And we've got a great training program on that
Taylor Cameron:and webinar that you can join. And don't know when the next
Taylor Cameron:date is Greg, but sure, we'll roll that out again. You need to
Taylor Cameron:have a documented policy and procedure segment, documenting
Taylor Cameron:everything that you say you're going to do, and then procedures
Taylor Cameron:allocated to each of those two areas. So we have two in our
Taylor Cameron:program. We have two procedure manuals. One is going to be for
Taylor Cameron:our front facing licensees. Front facing, I mean client
Taylor Cameron:facing licensees. And then one we have on the back end, which
Taylor Cameron:supports all of our compliance or admin staff on the back end,
Taylor Cameron:any anyone touching administrative documentation for
Taylor Cameron:vendor Act. The other pillar then becomes training. And then
Taylor Cameron:we have the effectiveness review, which comes around every
Taylor Cameron:two years. I think I've hit that right. We've got the compliance
Taylor Cameron:officer your documented policies, training,
Taylor Cameron:effectiveness review and risk. No,
Greg Dent:there you go. Yeah, that's the one you're missing.
Greg Dent:What you've just walked people through, in fact, is crucial to
Greg Dent:a business's opera, ability to have a complete compliance
Greg Dent:program, right? And, and what you've just walked people
Greg Dent:through, whether, whether, and it's subtle, but so let me kind
Greg Dent:of delve into this exactly. Touches on this, next two things
Greg Dent:that you had identified in the opening to this, which was a
Greg Dent:templates don't really work and or create a bunch of additional
Greg Dent:challenges. And the the other thing you had talked about was
Greg Dent:this idea of of risk rating your clients, and the importance of
Greg Dent:risk rating your clients. And so what you've just highlighted for
Greg Dent:me is is both of those things, because, on the one hand, it's
Greg Dent:basically impossible for you to have a consistent risk rating
Greg Dent:process if you're using several different methods of creating
Greg Dent:information records, client information records, and now I
Greg Dent:should put a bit of an asterisk in there. Our view of client
Greg Dent:information records are that IDV are a small part, or are a part
Greg Dent:of that client information record, and it's important to do
Greg Dent:your IDE verification properly, no question. But we've bundled
Greg Dent:it into the rest of the client information record, because
Greg Dent:that's generally how people are engaging with their clients. And
Greg Dent:the beauty of that is, if I can go back to the other thing
Greg Dent:you've said, which is the templates and the importance of
Greg Dent:weaving it all together is that when we weave that together
Greg Dent:operationally, we can then have a very clear answer to what is a
Greg Dent:low risk client. And you just can't do that. If you're picking
Greg Dent:somebody else's manual up and using it as your own, it just
Greg Dent:doesn't work. And I think that's the, that's the crux of one of
Greg Dent:the things that I've heard, like both of you say that that is
Greg Dent:the, and we spend a lot of time talking about this as a business
Greg Dent:with a lot of different people, is the specificity of your
Greg Dent:compliance program for your business is really, really
Greg Dent:important. Yeah,
Cagatay Sen:and Greg, to add to that point, I am very happy that
Cagatay Sen:we have a lot of buy in from these mortgage brokers and
Cagatay Sen:companies, etc, in respect of the development of the
Cagatay Sen:compliance program. Of course, the first step being that when I
Cagatay Sen:attain the appropriate information regarding their
Cagatay Sen:business and further insight into the risk, etc. I am
Cagatay Sen:responsible for the establishment of the
Cagatay Sen:documentation. And when I share the draft manuals, it's not just
Cagatay Sen:merely, oh, thank you. Let's move on. Kind of thing they want
Cagatay Sen:to ensure that you know it properly reflects the ongoing
Cagatay Sen:business model that they have. Ensure that you know that the
Cagatay Sen:all the information which is in the documentation is properly
Cagatay Sen:and easily understood by the staff, we're going to be able to
Cagatay Sen:revert to that when the time comes, etc. So I'm very happy
Cagatay Sen:that there, these guys are putting a lot of buy in into the
Cagatay Sen:development of these documentation just not merely
Cagatay Sen:accepting them because it's a requirement of the French leg
Cagatay Sen:obligations kind of thing? Yeah,
Greg Dent:yeah. No, it is. And that's, that's one of the things
Greg Dent:I first, my first bit of feedback to you was that you're
Greg Dent:absolutely right. Like it's been, it's been really nice to
Greg Dent:see how and I think it comes from being in a business where
Greg Dent:there was already a culture of compliance. Compliance as a
Greg Dent:concept isn't new to the mortgage sector. There are
Greg Dent:there's lots of check boxes and signed forms and things that
Greg Dent:need to happen for you to be able to process a mortgage deal.
Greg Dent:And I think that is more true for mortgage entities. Then it
Greg Dent:historically has been, necessarily, for the real estate
Greg Dent:sector. And we could, we could talk about that, and that's a
Greg Dent:whole host of problems on the real estate side of things. So
Greg Dent:kind of what's got side of the scope of today's conversation.
Greg Dent:But certainly, and I think what you've just highlighted for me
Greg Dent:is exactly that, that like these are businesses that really do
Greg Dent:want to have a good compliance posture on this stuff. They
Greg Dent:really don't want to be helping criminals launder money for lack
Greg Dent:of like, if we can go back to the brass acts of what this is
Greg Dent:all about, they take that obligation seriously, I think is
Greg Dent:what I'm hearing you say. Is that reflected in the
Greg Dent:conversations you're having as well? Taylor,
Taylor Cameron:yeah. I mean, again, going back to one of the
Taylor Cameron:comments I made earlier, that we have this, this population that
Taylor Cameron:don't really know what they don't know yet. And then we have
Taylor Cameron:the ones that know that there are things that they don't know.
Taylor Cameron:And it's, it's the ones that don't know what they don't know
Taylor Cameron:that I have the most fear for. You know, not completely
Taylor Cameron:understanding what it is that we're trying to do, not having
Taylor Cameron:enough knowledge to be able to understand the complexities of
Taylor Cameron:it and putting a full and complete program together. And
Taylor Cameron:then I think once we give them a little education, they go, Oh,
Taylor Cameron:crap, there's a lot more to this than we actually initially
Taylor Cameron:realized. And I think that's the place that, that's what we
Taylor Cameron:should be aiming for right now, is to be able to educate this
Taylor Cameron:market, or sort of this industry, to really allow them
Taylor Cameron:to understand what it is that we're doing here and the way
Taylor Cameron:that we need to be doing it, as well as the wise like, I mean,
Taylor Cameron:it was, I had a I had a consult just The other day, who said, I
Taylor Cameron:only do repeat business. Been doing this a long time. Further
Taylor Cameron:along into the conversation we were talking about I had shared,
Taylor Cameron:I've been a realtor for 16 years, and shared how once I've
Taylor Cameron:been with really trusted almost a year now, but coming out of
Taylor Cameron:the training that we provided, I look back on my career and was
Taylor Cameron:like, Holy crap. There's at least a half dozen individuals
Taylor Cameron:or clients that should have been marked as something more than a
Taylor Cameron:low risk and including a suspicious transaction. And he's
Taylor Cameron:like, You know what? Now that you say that I did have this one
Taylor Cameron:incident where somebody, it was a part of a drug cartel,
Taylor Cameron:somebody was knocked off. And the the remaining partners in
Taylor Cameron:this business setup came to me and and, and I'm like, did you
Taylor Cameron:ever like, Did you do anything with that information? He's
Taylor Cameron:like, No, I was scared. And I you know. But the point is, is
Taylor Cameron:that this conversation started with, I know all of my clients,
Taylor Cameron:we are all risk going to they had somebody that was knocked
Taylor Cameron:off. I'm like, okay, need I say more? So
Greg Dent:I would suggest to you that there will be a
Greg Dent:slightly higher level of risk in this transaction, and you became
Greg Dent:aware of it at some point in time. Whether that was before or
Greg Dent:after, the deal is somewhat irrelevant. You still had some
Greg Dent:sort of ongoing obligation here. So,
Taylor Cameron:yeah, so, I mean, it's been interesting, and
Taylor Cameron:I think if I can just touch on this, because I have, I've have
Taylor Cameron:such passion about this, is that we have to remember this is
Taylor Cameron:called money laundering, for a reason. This is the people that
Taylor Cameron:we are dealing with. This has gone through several channels.
Taylor Cameron:We're not dealing with the head of a cartel. We it's gone
Taylor Cameron:through several channels before. We are front facing with whoever
Taylor Cameron:it is that individual is. They're there to put down our
Taylor Cameron:defenses. They're there to be likable and really not want us
Taylor Cameron:to dive in and want us to believe the best in them. That's
Taylor Cameron:the whole purpose. So we can't go blindly into this and just
Taylor Cameron:say, really like them, you know that you know nothing we need to
Taylor Cameron:do the due diligence. We need to do that little extra bit of
Taylor Cameron:questioning and looking into this to make sure that we're not
Taylor Cameron:on, you know, we're not offside on on what they are trying to
Taylor Cameron:accomplish.
Greg Dent:Now you've just said we need to do this, and I
Greg Dent:completely agree with you, but some portion of the audience
Greg Dent:always says, right? But that's not my job. I'm not a police
Greg Dent:officer. How? How do each of you I have one response that I hope
Greg Dent:that somebody would say, but what would your answers be to
Greg Dent:that? Maybe chat. I do you want to take a crack at that and give
Greg Dent:us your thoughts on that.
Cagatay Sen:Well, this is, yeah, indeed, something that has
Cagatay Sen:come across, perhaps mostly in the real estate council meetings
Cagatay Sen:I had naturally. But I like to give this as well and just
Cagatay Sen:basically saying that you may feel that you're doing the work
Cagatay Sen:of the work of the regulatory authorities, etc. But I was
Cagatay Sen:telling that you know you are providing basically valuable
Cagatay Sen:intelligence information, which may be only one piece of the
Cagatay Sen:puzzle, but when you fulfill your obligation, especially in
Cagatay Sen:regards to something unusual, especially. Services, and you're
Cagatay Sen:submitting STR defense, right? That is very valuable
Cagatay Sen:information, which may, in the end, end up at the hands of the
Cagatay Sen:law enforcement agencies, etc, and they may bring down the all
Cagatay Sen:criminal gang, etc, things like that. So everybody has their
Cagatay Sen:proper role in respect of this process. Yes, it may be a burden
Cagatay Sen:just doing the additional control here and there, etc. But
Cagatay Sen:I mean, it is not something that they have to feel like they're
Cagatay Sen:doing alone, especially with the French work expense program that
Cagatay Sen:they signed up for. We were trusted. We have a whole support
Cagatay Sen:test, which is backing up their whole day to day activities.
Cagatay Sen:They just have to give us a call or send an email, and we always
Cagatay Sen:available to always provide that legislative guidance,
Cagatay Sen:elaboration as to what they have to do. They're not alone. It's
Cagatay Sen:something new for them. They don't necessarily feel like they
Cagatay Sen:have to do it at first instance, but this is what I said one day,
Cagatay Sen:that should shift the mindset happens. And that will happen
Cagatay Sen:with the day to day experiences, the training, awareness, etc.
Cagatay Sen:Things will be built up, etc. And they will then feel more
Cagatay Sen:comfortable that they have to be doing this, etc, and they want
Cagatay Sen:to be doing this, and they will be benefiting the whole system
Cagatay Sen:in general, in that regard.
Greg Dent:Lovely. And I completely buy into that part of
Greg Dent:things. And I think it's really important to call out that good
Greg Dent:compliance is actually just good business. I mean, as a business,
Greg Dent:I don't want to be working with a criminal for all sorts of
Greg Dent:reasons, reputational risk, fraud risk increases. Like they
Greg Dent:just the effort. And I guess here's the like from a from I
Greg Dent:think there's, like, some obvious, really good to society
Greg Dent:parts of things, and you've just kind of really well elaborated
Greg Dent:on that, in fact. But I think beyond that, just like, Let's go
Greg Dent:really selfish for a second. I'm running a business. It costs me
Greg Dent:money when I spend a bunch of time working with somebody who
Greg Dent:ends up being fraudulent and I therefore don't get paid, or end
Greg Dent:up getting dragged into a lawsuit, or getting up get out,
Greg Dent:being investigated by somebody having a production order,
Greg Dent:having to spend the time to deal with the production order before
Greg Dent:I even get to the reputational risk of being the guy who gets
Greg Dent:published in the newspaper as the one who was involved in the
Greg Dent:drug trafficking ring and all those things. So there's,
Greg Dent:there's both, I think, a really good to society, part of things
Greg Dent:that that just, well, look, you have an obligation, and so you
Greg Dent:might as well. But also, from a good business point of view, it
Greg Dent:is insane to me that a reporting entity would willfully choose to
Greg Dent:not put into in place some form of safeguards to protect
Greg Dent:themselves against all of the elements of fraud that might be
Greg Dent:perpetrated within their business otherwise. So I think
Greg Dent:there's kind of the both sides of that, to me, are really
Greg Dent:powerful. I'm looking at the clock. Taylor, you look like
Greg Dent:you've got something you want to wrap up. Go ahead. Yeah, and I
Greg Dent:would
Taylor Cameron:just wanted to say, you know, we it is like
Taylor Cameron:chat. I said it is a piece of a puzzle. So when we have, you
Taylor Cameron:know, the banking system doing a report on somebody, and then,
Taylor Cameron:you know, the conversations are having with a bank versus the
Taylor Cameron:conversations clients are having with me as a realtor, when I'm
Taylor Cameron:showing a property, everything is really relaxed. Their guard
Taylor Cameron:is down. Is then a different conversation that they're having
Taylor Cameron:with a mortgage broker, and it is a piece of a puzzle. And I
Taylor Cameron:think we also have these two thoughts that, you know what,
Taylor Cameron:when we report something, it goes into a dark void, and we
Taylor Cameron:never know anything that happens. And then we have the
Taylor Cameron:other school of thought that is, oh, my God, I'm gonna risk
Taylor Cameron:somebody as high or assessment as a high risk, and you know,
Taylor Cameron:they're, you know, CIA is gonna come banging on their door and,
Taylor Cameron:you know, tear apart their home. And the reality is, is that we
Taylor Cameron:are not going to know. We're not always going to know the impact
Taylor Cameron:that we have. You know, Greg and I, you and I have traveled a lot
Taylor Cameron:in the in September, when we sat at tables and rubbed shoulders
Taylor Cameron:with a lot of people from chinchak, and their ability to
Taylor Cameron:disclose a lot of information is also withheld, so similar to, if
Taylor Cameron:we have witnessed an accident and and we take somebody and
Taylor Cameron:drop them off at a hospital, we are not privileged to their
Taylor Cameron:medical well being after we drop them off, but we have to know
Taylor Cameron:that we had an impact. And so I think that's just, I just wanted
Taylor Cameron:to end on that note, that we all have a piece of the puzzle to
Taylor Cameron:create and build and and we should all take it seriously and
Taylor Cameron:and that we are doing something for the betterment of our, of
Taylor Cameron:all of us,
Greg Dent:that's a really positive way to end this. So
Greg Dent:thank you for that. I love it. That's terrific. All right,
Greg Dent:guys. Well, thank you very much. Taylor, thank you. Thank you
Greg Dent:very much. Chant, I really appreciate you both joining me
Greg Dent:and having this conversation. I do hope that for our listening
Greg Dent:audience, you'll be able to take away some thoughts as to if
Greg Dent:you're a mortgage entity listening to this, I hope you've
Greg Dent:you're considering what we've said from your point of view.
Greg Dent:Um. Um and and you know, if any of what what we've said rings
Greg Dent:true as challenges you might be facing, give us a shout. We're
Greg Dent:happy to help. That's that's certainly what we do. If you're
Greg Dent:looking at this, if you're not a mortgage entity and you're
Greg Dent:you've listened this far, well, thank you for joining us. I hope
Greg Dent:that we've managed to to give you some insight into it, a
Greg Dent:different sector of the world, and managed to help you
Greg Dent:understand how other people are grappling with their reporting
Greg Dent:obligations, as it were. Thank you very much. Folks. Have a
Greg Dent:wonderful day.
Taylor Cameron:Thanks everyone.
