Anti-Money Laundering Independent Audit Review Checklist

Date of Review ______

Review performed by ______[1]

Fuller Center covenant partner’s designated compliance officer ______

Does the board have a succession plan in the event of compliance officer turnover? Yes / No

Review of financial operations:

Is a signed copy of The Fuller Center for Housing - Anti-Money Laundering Policy Statement & Program Procedures kept on file? Yes / No

Date of approval of the policy by covenant partner board of directors ______

Does the covenant partner have segregated duties with regard to handling, recording and reporting of financial transactions to the board of directors? Yes / No

List individuals responsible for:

Homeowner applications and customer identification ______

Are customer identification forms found in files for approved applications? [2] Yes / No

How many files were reviewed? ______

Are all applicants checked on the Treasury Department’s Specially Designated Nationals
and Blocked Persons List Search? http://sdnsearch.ofac.treas.gov/ Yes / No

Person(s) authorized to execute promissory notes, liens, and deeds of trusts ______

Individual(s) authorized to make deposits ______

Individual(s) responsible for bookkeeping ______

Are records kept in a locked place? Yes / No

Individual(s) authorized to disburse funds ______

Are two signatures required on all checks? Yes / No

Are funds held in trust or escrow comingled with general or personal accounts? Yes / No

Individual(s) responsible for reconciling checking and savings accounts ______

______

How often are reports provided to the board of directors? ______

Is the designated compliance officer acquainted with the Suspicious Activity Report electronic filing website for Currency Transaction Reports (CTRs) and Suspicious Activity Reports (SARs)?[3] http://bsaefiling.fincen.treas.gov/main.html Yes / No

Person(s) responsible for filing a Currency Transaction Report and Suspicious Activity Reports ______

Is the designated compliance officer aware of the requirement to preserve SAR and accompanying documentation for 5 years? Yes / No

Describe covenant partner’s risk for money laundering:

______

Describe covenant partner’s staff training procedures:

______

Assess overall effectiveness of suspicious activity monitory systems used for AML compliance:

______

Have any Suspicious Activity Reports been reported by the covenant partner? Yes / No

If yes, was the Fuller Center for Housing –Anti-Money Laundering Policy procedures followed? Yes / No

If no, attach a violation report and recommended resolutions for compliance officer and board of directors review.

Evaluate management’s efforts to resolve violations and deficiencies noted in previous audits and regulatory examinations, including progress in addressing supervisory actions, if applicable:

______

Additional comments:

Signature Independent Auditor ______Date ______

Signature Compliance Officer ______Date ______

Signature Covenant Partner Treasurer______Date ______

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[1] Independent Review cannot be performed by the covenant partner’s designated compliance officer

[2] Required for all customers with loans after August 13, 2012

[3] Fuller Center covenant partners must report suspicious activities related to transactions of at least $5,000 or involving funds derived from or intended to disguise illegal activity. Suspicious activity also includes businesses in which a partner family, vendor or subcontractor would not normally be expected to engage.