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March 2009

PREPARED REMARKS OF JAMES H. FREIS, JR. DIRECTOR, FINANCIAL CRIMES ENFORCEMENT NETWORK

Good morning. I am honored to open this morning’s panel which will provide an industry update in the fight against mortgage fraud. Among the considerable challenges facing the mortgage finance industry - from reduced originations, to an unprecedented volume of repurchase requests, and a record number of delinquent loans – to name a few, we unfortunately must include mortgage fraud on this list.

FinCEN Issues Ruling (FIN-2009-R001) on Whether Certain Operations of a Service Provider to Prepaid Stored Value Program Participants is a Money Services Business


FIN-2009-R001Issued: January 22, 2009Subject: Whether Certain Operations of a Service Provider to Prepaid Stored Value Program Participants is a Money Services Business

Dear [ ]:

I am responding to your letter of September 20, 2005 to the U.S. Department of the Treasury. You seek a determination as to whether your client, [] ("the Company"), is a money services business ("MSB") as that term is defined in our regulations by virtue of having entered into a distributorship agreement with [] ("the Arranger").