Draft requirements for AML/CTF (Anti-Money Laundering/Counter Terrorism Financing) are up in the Applications Working Group area on the LIXI site. Unfortunately it is far from easy to pin down just what the actual requirements will be - lenders have a fair bit of discretion about how they comply, plus they have a long non-prosecution period which makes them feel relaxed and comfortable about getting this work done. Which is great for them but LIXI needs to have updated standards available in time to support the first lender's who comply - which could be as early as the official start date of December 13.
Brokers are also facing this problem in that of course they don't want to have to comply with differing processes from every lender, but it is difficult for them to "encourage" lenders to agree on a common process (let alone do so quickly). Thankfully the MFAA has in fact made a lot of progress and has already prepared a solid draft common approach. I've used this common approach as a starting point for determining what will have to change in LIXI/CAL, but the bottom line is that the requirements I've published are still largely just my informed guesses and interpretations. We really need lenders to get in and review the requirements and comment on their completeness or otherwise, and this needs to happen SOON. To have CAL updated in time for implementations that may go live as early as Dec.13 we have absolutely no time to waste.
I know a lot of lenders are thinking that they'll just institute manual processes in parallel with the existing electronic submissions, and of course this can be workable in the short term. But really, it's going to annoy customers and brokers - and no lender can afford to do that for long in a competitive environment. It is in everyone's interests for us to get a comprehensive, LIXI-compliant solution in place ASAP.
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