Comment on FR Doc # 2010-30765

While the proposal by FINCEN's Anti-money Laundering Reporting Rules for Non-Bank Mortgage Lenders and Brokers seems reasonable in the fight against fraud and money laundering, I believe it is onerous to expect small business to comply. Most small mortgage brokers employ less than five persons and there is no distinction in the proposed rules to exempt such small companies or sole proprietorships. The rules require designating compliance officers and employee training. In small companies this will fall on the owner who already spends more time on paperwork and regulations than they do on generating business. And who do you expect them to report suspicious activity on? To say that these small companies already have AML programs in place that will complement the anti-fraud and general compliance programs that residential mortgage lenders and originators have established to comply with the SAFE Act and other Federal and State laws and protect their own business operations just demonstrates a total disconnect from the realities of a small business. "Many residential mortgage lenders and originators may be able to integrate risk-based AML reporting programs into existing enterprise-wide, anti-fraud, and compliance programs in a complementary manner that utilizes efficiencies and commonalities and enhances the effectiveness of a business’s compliance measures. As noted, these businesses also may have procedures in place to prevent fraud, which they may be able to integrate into their AML programs". This statement does not apply to a single one of the small originators that I know in our organization. I respectfully request that this proposal should be withdrawn or companies with less than 5 employess should be exempt from complying.