In this episode, Greg delves into the real estate industry's ongoing struggles with FINTRAC (Financial Transactions and Reports Analysis Centre of Canada) compliance. Drawing from his extensive experience training thousands of real estate agents, Greg unpacks the unique challenges the sector faces in adhering to anti-money laundering and counter-terrorist financing regulations. He explores the industry's structural issues, misaligned incentives, regulatory pressures, and the need for a shift in the "tone from the top" to drive meaningful compliance.

Key Takeaways:

• The real estate industry's fragmented, small-business structure poses inherent challenges in implementing robust FINTRAC compliance programs.
• Misaligned incentives, where agents' sales-driven focus can conflict with compliance obligations, contribute to the industry's struggles.
• Regulatory changes and the "compliance squeeze" have overwhelmed many real estate brokerages, leaving them with limited bandwidth to prioritize FINTRAC requirements.
• Industry leaders' perceived indifference towards FINTRAC compliance has trickled down, leading some agents to believe that form-filling alone is sufficient.
• Targeted FINTRAC training and compliance support programs can help real estate brokerages better understand and fulfill their obligations, driving improved reporting and risk management.

Connect with Greg and ReallyTrusted at:

https://reallytrusted.com/

https://www.facebook.com/ReallyTrusted/

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Greg Dent: 00:00:00

Hello and welcome to another episode of The know your

Greg Dent: 00:00:03

compliance podcast, the KYC podcast. My name is Greg Dent,

Greg Dent: 00:00:07

and I'm the host of the podcast. Today, we're going to do

Greg Dent: 00:00:10

something a little bit different. I'm going to spend a

Greg Dent: 00:00:13

little bit of time chatting with you about my observations of the

Greg Dent: 00:00:18

real estate sector as they relate to their anti money

Greg Dent: 00:00:22

laundering, counter terrorist financing obligations, or their

Greg Dent: 00:00:25

FINTRAC obligations. And I'm going to start with just kind of

Greg Dent: 00:00:29

explaining why I'm qualified to speak to this very topic. I've

Greg Dent: 00:00:34

been a real estate agent now for over 14 years, and I've been

Greg Dent: 00:00:39

studying FINTRAC and anti money laundering for about seven years

Greg Dent: 00:00:43

now, and so I think it is entirely possible also that I've

Greg Dent: 00:00:48

talked with more compliance officers or brokers of record or

Greg Dent: 00:00:52

managing brokers in this country, possibly than anyone

Greg Dent: 00:00:56

else about specifically

Greg Dent: 00:00:58

about their FINTRAC obligations. I'm not sure, but that's

Greg Dent: 00:01:03

probably true. And what's interesting to that about that

Greg Dent: 00:01:07

is that I've had so many different conversations that I

Greg Dent: 00:01:13

actually don't think there's any conversations left to have that

Greg Dent: 00:01:15

I haven't had with somebody at some point. And so I'm able to

Greg Dent: 00:01:18

kind of talk about some of the challenges that the sector has

Greg Dent: 00:01:21

in general and some of the specific challenges we've seen

Greg Dent: 00:01:25

as we at really trusted have unveiled our FINTRAC compliance

Greg Dent: 00:01:30

programs and our assistance with FINTRAC compliance programs. So

Greg Dent: 00:01:35

actually, one other thing that I think is important that makes me

Greg Dent: 00:01:39

somewhat qualified to speak about this is I've now delivered

Greg Dent: 00:01:42

training on fan track, on anti money laundering, on counter

Greg Dent: 00:01:47

terrorist financing, to hundreds and actually, definitely into

Greg Dent: 00:01:52

the 1000s, 1000s of real estate agents in Canada, and the

Greg Dent: 00:01:58

feedback and the questions that they've asked to help inform my

Greg Dent: 00:02:01

understanding. So I think I am somewhat qualified to talk about

Greg Dent: 00:02:04

this, and that's what I'm qualified to talk about. That's

Greg Dent: 00:02:07

what you're going to get to listen to today. So if you're

Greg Dent: 00:02:09

interested in about how the real estate industry has done with

Greg Dent: 00:02:14

their fin track obligations, or how it hasn't done and I mean,

Greg Dent: 00:02:20

some people would even ask, how the heck it's possible that they

Greg Dent: 00:02:23

still haven't figured it out is, is? And when I talk with folks

Greg Dent: 00:02:26

in the AML CTF space, that's certainly their feeling is, how

Greg Dent: 00:02:32

the heck is it that an industry is over 15 years into its

Greg Dent: 00:02:36

regulation and still doesn't understand and so I want to

Greg Dent: 00:02:40

start to try and address that question today as I kind of talk

Greg Dent: 00:02:43

about the challenges the industry has faced. So that's

Greg Dent: 00:02:46

that's what I'm going to do. Let's call let's launch right

Greg Dent: 00:02:49

into it. I don't have any other guests to introduce. It's just

Greg Dent: 00:02:52

me. So let's launch right into it today. I think there's kind

Greg Dent: 00:02:57

of four things that I think really make it difficult for the

Greg Dent: 00:03:02

real estate sector to adequately comply with FINTRAC. And look, I

Greg Dent: 00:03:08

think let's, let's lay the groundwork for this whole thing.

Greg Dent: 00:03:13

I'm recording this in mid 2024, over the last handful of years,

Greg Dent: 00:03:19

FINTRAC has regularly published fines somewhere between four to

Greg Dent: 00:03:23

six real estate brokerages most years get published. The average

Greg Dent: 00:03:28

fine has been $143,000 and fin track as recently as a couple

Greg Dent: 00:03:35

years ago, when they did the AML CTF virtual forum for the real

Greg Dent: 00:03:40

estate sector was abundantly clear that they believe quite

Greg Dent: 00:03:44

strongly that our reporting are the real estate sectors

Greg Dent: 00:03:47

reporting of suspicious transactions specifically is way

Greg Dent: 00:03:55

below what it should be by numbers. And I think they're

Greg Dent: 00:04:00

probably right. I think that's where the question starts to

Greg Dent: 00:04:05

form. Is it because the industry's in on it? Is it

Greg Dent: 00:04:08

because the industry's ignoring it? The is the industry just not

Greg Dent: 00:04:13

is the industry supporting money laundering? That's That's one of

Greg Dent: 00:04:16

the questions I've had some people, people ask, and I don't

Greg Dent: 00:04:20

think any of that's true. I think the the reality is,

Greg Dent: 00:04:24

here's, here's, here's my view on it. And I'm going to qualify

Greg Dent: 00:04:26

all of this by saying, Look, this is my take on all of this.

Greg Dent: 00:04:32

I think I'm qualified to speak on it, but, but others, my

Greg Dent: 00:04:35

others certainly can and do have other opinions. So I cluster all

Greg Dent: 00:04:41

of the problems into kind of three or four things. One is the

Greg Dent: 00:04:44

structure of the industry. Two is and this is somewhat related,

Greg Dent: 00:04:49

but there's kind of a misaligned incentives portion of this, and

Greg Dent: 00:04:53

that's true in other sectors. So that's not unique to real

Greg Dent: 00:04:55

estate, but there is a misaligned incentives problem.

Greg Dent: 00:04:59

There's a. Challenge that the tone from the top hasn't always

Greg Dent: 00:05:05

been as supportive of AML as it probably should, could have

Greg Dent: 00:05:10

been, and I'll unpack that in a second as well. And then there's

Greg Dent: 00:05:13

the regulatory squeeze, and I think that's something that

Greg Dent: 00:05:17

across the real estate sector, people are certainly feeling so

Greg Dent: 00:05:20

So let's delve into each of those a little bit, and I'll

Greg Dent: 00:05:22

kind of unpack what I mean when I say all those things. So let's

Greg Dent: 00:05:25

start with the structure, because I think the structure is

Greg Dent: 00:05:28

the one that I've had pushback on this from people within the

Greg Dent: 00:05:34

industry. And I guess the funny thing to me is the challenge

Greg Dent: 00:05:38

within our within this real estate sector, and why I talk

Greg Dent: 00:05:42

about the structure being a problem is a couple of different

Greg Dent: 00:05:45

things. First of all, the real estate sector is a ton of small

Greg Dent: 00:05:53

businesses, occasionally medium sized businesses, but mostly

Greg Dent: 00:05:57

small mom and pop operations. I hang my license at a brokerage

Greg Dent: 00:06:01

of 75 agents, which is kind of medium size, I suppose, for the

Greg Dent: 00:06:06

real estate sector. But if you go look at the financials of

Greg Dent: 00:06:10

that business, there's a total of, I don't know, three or four

Greg Dent: 00:06:14

full time staff. It's not a massive operation. There's not

Greg Dent: 00:06:17

huge profits. There's not huge revenues, in fact. So when you

Greg Dent: 00:06:22

realize that my medium sized brokerage is still very much a

Greg Dent: 00:06:26

small business, you realize that one of the challenges they're

Greg Dent: 00:06:30

going to have is compliance. Therefore is a large is going to

Greg Dent: 00:06:34

be a large cost, unless you find a way to deliver that within the

Greg Dent: 00:06:39

structures you already have. And that's the next part of things

Greg Dent: 00:06:42

is that most of these small businesses are owned and

Greg Dent: 00:06:48

operated by real estate agents who became owners, who became

Greg Dent: 00:06:54

brokerages, who became owners of brokerages, often become the

Greg Dent: 00:06:58

managing broker or broker of record of those brokerages,

Greg Dent: 00:07:01

because that's the next natural step in their progression, not

Greg Dent: 00:07:05

necessarily because they wanted to run a business, but because

Greg Dent: 00:07:08

they were running a business of sales and saw an opportunity to

Greg Dent: 00:07:12

run a bit more of a consistent business and or have a deep

Greg Dent: 00:07:16

desire to support and train others and form and have

Greg Dent: 00:07:19

leadership that way. But in all of those cases, I can almost

Greg Dent: 00:07:24

assure you that there is no broker in this country who got

Greg Dent: 00:07:27

into owning a brokerage because they wanted to make sure that

Greg Dent: 00:07:30

their fin track obligations were properly addressed. I kind of

Greg Dent: 00:07:34

smile when I say that, because it's so obvious, but I think my

Greg Dent: 00:07:37

point here is that compliance is, is one of the things they're

Greg Dent: 00:07:42

obligated to do, but it's not something that they're super

Greg Dent: 00:07:46

inspired by, and it's not something they particularly want

Greg Dent: 00:07:48

to do. And I don't mean just their AML, CTF compliance.

Greg Dent: 00:07:51

There's other compliance. We'll talk more about that in a

Greg Dent: 00:07:53

second, when I talk about the regulatory squeeze. And so I

Greg Dent: 00:07:58

think the very structure is, is problematic, Faith part two of

Greg Dent: 00:08:03

the structure still being problematic. There's, there's

Greg Dent: 00:08:06

actually three parts to the structure itself. Part two is

Greg Dent: 00:08:10

that the vast majority of brokerages have agents who hang

Greg Dent: 00:08:15

their license at a brokerage, but those agents are independent

Greg Dent: 00:08:18

contractors, and that creates a real problem for the broker

Greg Dent: 00:08:23

owners who have these responsibilities of fin track

Greg Dent: 00:08:27

compliance program in for the purposes of our conversation

Greg Dent: 00:08:29

today, but whose staff are constantly whose whose staff,

Greg Dent: 00:08:35

whose agents, and I shouldn't use the term, staff whose agents

Greg Dent: 00:08:40

are essentially customers. They're customers. If I'm an

Greg Dent: 00:08:43

agent hanging my license at XYZ brokerage, I can move my license

Greg Dent: 00:08:50

to some other brokerage like that, just a snap of a button, I

Greg Dent: 00:08:55

can move my license to somebody else. And so if I impose

Greg Dent: 00:08:59

significant burdens on an agent's doing their business,

Greg Dent: 00:09:03

whether that's a financial burden or a time burden, doing

Greg Dent: 00:09:06

some sort of additional form or paperwork, no matter how right

Greg Dent: 00:09:09

it must be. Might be sorry, it's competitive marketplace, and so

Greg Dent: 00:09:14

I risk losing agents when I do the right thing, from a

Greg Dent: 00:09:19

compliance point of view, because the brokerages across

Greg Dent: 00:09:23

the street might not be doing all the same things. And so

Greg Dent: 00:09:26

there's a there's an additional kind of structural problem

Greg Dent: 00:09:30

there. And I think the last part of the structural problems, this

Greg Dent: 00:09:35

is more about misaligned incentives, maybe, but it's

Greg Dent: 00:09:39

certainly part of the structure as well, is that, by definition,

Greg Dent: 00:09:42

the real estate sector is a sales organization, or is a

Greg Dent: 00:09:45

sales driven industry, and your the agent makes money every time

Greg Dent: 00:09:52

they do a sale, therefore they want to be doing sales. And so

Greg Dent: 00:09:59

there is an element. And of I mean, to use the really

Greg Dent: 00:10:05

aggressive term, there is an element of willful blindness

Greg Dent: 00:10:08

that might exist in some cases, at the very least, they agents

Greg Dent: 00:10:13

don't have incentives to stop doing deals for some sort of a

Greg Dent: 00:10:17

regulatory burden or for some sort of a hiccup on the

Greg Dent: 00:10:21

compliance front. And now look, I I've spent time on other

Greg Dent: 00:10:26

episodes of this show talking about why compliance is

Greg Dent: 00:10:29

important and compliance is the right business decision, and why

Greg Dent: 00:10:32

it saves businesses of all sorts money and time and all the rest.

Greg Dent: 00:10:37

So I'm not going to get into that here, but the nature of

Greg Dent: 00:10:41

real estate is such that the agent, the frontline person, the

Greg Dent: 00:10:44

person who's dealing with the consumer who's might be

Greg Dent: 00:10:47

laundering money, generally speaking, that agent has an

Greg Dent: 00:10:52

inverse incentive to make sure that they stop that transaction.

Greg Dent: 00:10:57

And so that becomes a, obviously a structural problem as well.

Greg Dent: 00:11:01

Now, I think the the next part about, if we now that we're kind

Greg Dent: 00:11:06

of on the topic of misaligned incentives, I think I should

Greg Dent: 00:11:09

kind of point out there is an additional challenge, which is

Greg Dent: 00:11:12

that many times agents are working with people who they

Greg Dent: 00:11:15

know, or they feel they know. When I think about my clients,

Greg Dent: 00:11:18

many of our many of my clients are, are people who are referred

Greg Dent: 00:11:23

to me by people I've previously done deals with. And so I kind

Greg Dent: 00:11:26

of feel like I've got this closeness with them on some

Greg Dent: 00:11:29

level. And sometimes they're, they're friends their family,

Greg Dent: 00:11:33

they're they're people at my church, they're people from my

Greg Dent: 00:11:36

kids soccer team, they're people from all of those kinds of

Greg Dent: 00:11:38

groups. And so you have these relationships. They're my

Greg Dent: 00:11:41

neighbors, and so you have this relationship, and you don't, you

Greg Dent: 00:11:46

don't want to believe that it's possible that those people are

Greg Dent: 00:11:49

laundering money. And there are many, many, many, many, many

Greg Dent: 00:11:52

times I've talked with real estate agents in this country

Greg Dent: 00:11:55

who have said to me, oh, it's not possible for my client, for

Greg Dent: 00:11:58

my clients, ever to be laundering money. I know them

Greg Dent: 00:12:00

all so very well. It's not possible. It's just not

Greg Dent: 00:12:03

something they would do, as though all of their all of their

Greg Dent: 00:12:06

clients, are from this perfectly close knit group that they know

Greg Dent: 00:12:11

extremely well. And I, again, I don't need to delve into on this

Greg Dent: 00:12:15

podcast. Certainly, I think listeners of this podcast are

Greg Dent: 00:12:17

going to understand that my neighbor is just as it's just as

Greg Dent: 00:12:21

possible for them to be laundering money as it is for

Greg Dent: 00:12:23

anybody else. But that is the challenge that the industry

Greg Dent: 00:12:29

faces, and part of the reason why reporting, I think, has been

Greg Dent: 00:12:32

so low, ultimately, I want to move to to the regulatory

Greg Dent: 00:12:37

squeeze. I've made reference to it a couple of times, and I

Greg Dent: 00:12:40

guess that's the other part of the that's another. There's kind

Greg Dent: 00:12:43

of two other things I'm going to talk about, the regulatory

Greg Dent: 00:12:45

squeeze is the next one. And when I think about the

Greg Dent: 00:12:47

regulatory squeeze, we were looking at an industry that's

Greg Dent: 00:12:51

been under the gun from governments across the country,

Greg Dent: 00:12:56

because in Canada, we have a housing crisis. I think that's I

Greg Dent: 00:13:03

don't even think that's controversial anymore as a

Greg Dent: 00:13:05

concept. I think everybody's kind of agreed that that that is

Greg Dent: 00:13:08

the truth. And what that's meant is that governments across the

Greg Dent: 00:13:12

country have done whatever they can to help regulate that,

Greg Dent: 00:13:17

speaking in BC, we've seen massive regulatory changes in

Greg Dent: 00:13:23

the last decade, easily from and I think that's that's most

Greg Dent: 00:13:29

evident in the amount of paperwork that is now being done

Greg Dent: 00:13:34

on every single deal, the various aspects that every

Greg Dent: 00:13:38

single deal must Now touch and to give you some specific

Greg Dent: 00:13:42

examples, in BC, we now have a rescission program. We have a

Greg Dent: 00:13:46

foreign buyer tax. We have differing levels of property

Greg Dent: 00:13:49

transfer tax. Every level of government, if you're working in

Greg Dent: 00:13:52

the city of Vancouver, every level of government, local,

Greg Dent: 00:13:56

provincial and federal, all have a vacancy tax. The and you as an

Greg Dent: 00:14:02

agent, you need to know all of these things. As a brokerage, as

Greg Dent: 00:14:04

a as a managing broker, you need to understand all of these

Greg Dent: 00:14:07

things to be able to inform your agents on them. And that's just

Greg Dent: 00:14:10

beginning to cut to open it up. I mean, in BC, dual agency is no

Greg Dent: 00:14:15

longer allowed. There's a disclosure requirement around

Greg Dent: 00:14:19

the expected remuneration. There's all of these additional

Greg Dent: 00:14:22

levels of new ish things, and that shifting framework means

Greg Dent: 00:14:28

that a for a for that owner of the mom and pop shop, there's

Greg Dent: 00:14:33

just a need to continue their education. And look, that's

Greg Dent: 00:14:36

wonderful. That's the point of being a professional. I think

Greg Dent: 00:14:39

that's terrific. But FINTRAC is just one more thing that they

Greg Dent: 00:14:45

need to be educating themselves about, and it's just it's so

Greg Dent: 00:14:49

tangential to what they're actually want to be doing in the

Greg Dent: 00:14:52

first place that most of them just don't most of them just

Greg Dent: 00:14:57

don't have the capacity either, either they don't want. To or

Greg Dent: 00:15:00

they just literally don't have the capacity, but, but my point

Greg Dent: 00:15:03

is that actually, let me even get a step further back, when

Greg Dent: 00:15:08

you own a real estate brokerage, your business is the business of

Greg Dent: 00:15:14

recruiting new agents, training and assisting your current

Greg Dent: 00:15:18

agents and making them successful. The compliance stuff

Greg Dent: 00:15:23

is stuff you do because that's the actual business. That's how

Greg Dent: 00:15:25

the business is expressed. That's where the money comes.

Greg Dent: 00:15:27

But your success truly is measured on your ability to keep

Greg Dent: 00:15:32

your current agents and recruit new ones. That's when you're

Greg Dent: 00:15:36

running a brokerage. The constant goal is to add new well

Greg Dent: 00:15:40

qualified in most brokerages. Cases, agents to the pilot and

Greg Dent: 00:15:45

look, that's going to change depending on your brokerage

Greg Dent: 00:15:47

model. Sometimes it's just a sheer number thing. Sometimes

Greg Dent: 00:15:49

it's quality as well. But the point is that your job as a

Greg Dent: 00:15:53

broker, owner of a real estate brokerage, is to make sure that

Greg Dent: 00:15:56

you have sales people doing the job, and to help those

Greg Dent: 00:16:00

salespeople do the job. All of the compliance stuff is one more

Greg Dent: 00:16:08

thing that's thrust upon you and and honestly, what ends up

Greg Dent: 00:16:13

happening for most broker owners is they just don't have the

Greg Dent: 00:16:16

capacity to learn about FINTRAC, to learn about their anti money

Greg Dent: 00:16:21

laundering obligations to the level of detail that it takes to

Greg Dent: 00:16:25

be successful at it. And so that's somewhat of a structural

Greg Dent: 00:16:30

problem that's so much of a regulatory squeeze problem, but

Greg Dent: 00:16:32

ultimately, it expresses itself as most brokerages in this

Greg Dent: 00:16:35

country and most broker owners in this country just not being

Greg Dent: 00:16:41

able to have the bandwidth to deliver, implement and maintain

Greg Dent: 00:16:48

and operate a fin track compliance program. And that's

Greg Dent: 00:16:51

that's the insight, I think, that my team and I came up with

Greg Dent: 00:16:54

about three or four years ago as we started to push towards the

Greg Dent: 00:16:57

delivery of what we now call fin track Express, where we take on

Greg Dent: 00:17:01

all of that responsibility. Well, not all, but where we take

Greg Dent: 00:17:04

on the the the creation of and the maintenance of the fin track

Greg Dent: 00:17:08

compliance program. And we put broker owners in a position

Greg Dent: 00:17:12

where they can just operate the program. That's the the insight.

Greg Dent: 00:17:15

The reason we went down that path was because we saw broker

Greg Dent: 00:17:19

owners everywhere drowning in their fin track obligations as

Greg Dent: 00:17:23

just being the the needle, the hay that broke the camel's back,

Greg Dent: 00:17:28

right? It's the one more thing that they had to do. There is

Greg Dent: 00:17:32

one other thing, and I haven't mentioned it yet, because I'm

Greg Dent: 00:17:35

always a little weary of this, because I don't want to offend

Greg Dent: 00:17:37

people in the industry, but I will say that the other

Greg Dent: 00:17:41

challenge from within the industry is that the tone of the

Greg Dent: 00:17:43

top hasn't always been great on this topic. And I think that

Greg Dent: 00:17:49

again, and this isn't there's no one organization or association

Greg Dent: 00:17:54

or anything that I think is particularly guilty of this.

Greg Dent: 00:17:56

Quite the contrary, I think every level of association are

Greg Dent: 00:18:01

the Canadian Real Estate Association, the BC Real Estate

Greg Dent: 00:18:03

Association, the Ontario Real Estate Association, the local

Greg Dent: 00:18:07

boards that support them, or that, sorry, that create the

Greg Dent: 00:18:11

local level of and and even the broker owners in the offices at

Greg Dent: 00:18:15

below that. I think everybody on some level in the back their

Greg Dent: 00:18:20

mind, and some say it quite vocally, think that FINTRAC is

Greg Dent: 00:18:24

going to go away. And want fin track to go away because we saw

Greg Dent: 00:18:27

the lawyers get out of their fin track obligations, or because

Greg Dent: 00:18:30

it's new for them, then, therefore it's probably not

Greg Dent: 00:18:33

going to make it, or something like that. And that, what that's

Greg Dent: 00:18:38

meant is that every time a leader within the industry

Greg Dent: 00:18:42

stands up and says, Well, FINTRAC, it's just one other

Greg Dent: 00:18:45

thing that we have to do. Or, you know, you just fill out

Greg Dent: 00:18:48

those forms and you're good, or whatever, some some version that

Greg Dent: 00:18:51

doesn't express the depth of what fin tracks really about,

Greg Dent: 00:18:54

and the and the importance of a business monitoring and managing

Greg Dent: 00:18:59

its risks specifically and obviously in our cases, around

Greg Dent: 00:19:02

AML, CTF, every time somebody does that, it's just a little

Greg Dent: 00:19:06

chip into the importance and the validity of the FINTRAC

Greg Dent: 00:19:12

compliance programs that the broker owner just might or might

Greg Dent: 00:19:15

not in many cases, implement. So I guess the tone from the top,

Greg Dent: 00:19:20

and again, I don't want to belabor the point, but

Greg Dent: 00:19:24

everybody's done what they can to help support the agent at the

Greg Dent: 00:19:29

end of the day, but it's so diluted by the time it gets to

Greg Dent: 00:19:33

the agent that many agents I and I would I know this is true

Greg Dent: 00:19:38

because Almost every week, I have a conversation with an

Greg Dent: 00:19:42

agent somewhere who says to me, well, as long as I'm filling out

Greg Dent: 00:19:47

the forms, I'll be fine, right?

Greg Dent: 00:19:50

And I think our listeners will probably understand that that's

Greg Dent: 00:19:54

obviously not the truth, and it's not coming from a place of

Greg Dent: 00:19:58

not wanting to go. Apply. It's coming from a place where our

Greg Dent: 00:20:02

industry has told them, here is the form that you need to fill

Greg Dent: 00:20:07

out, and as long as you fill that out, you'll have fulfilled

Greg Dent: 00:20:10

your fin track obligations, which obviously is wrong and

Greg Dent: 00:20:15

which obviously just doesn't work. Anybody who understands

Greg Dent: 00:20:19

fin track will understand that filling in a form is not what

Greg Dent: 00:20:22

you need to be doing, thinking it through and understanding

Greg Dent: 00:20:25

what you're looking at and making determinations based on

Greg Dent: 00:20:29

what you're seeing. That's what fin tracks about. The form is

Greg Dent: 00:20:32

the way of documenting that, and unfortunately, in the desire for

Greg Dent: 00:20:38

creating a simple way of of complying. Our bro, our

Greg Dent: 00:20:43

industry, has spent 15 years teaching agents that as long as

Greg Dent: 00:20:47

you fill in this one form, you'll have fulfilled your fin

Greg Dent: 00:20:49

track obligations. So I wanted to riff a little bit on this

Greg Dent: 00:20:54

topic, because I think that lot of people in the AML, CTF space,

Greg Dent: 00:20:59

anyway, don't understand why real estate agents, why real

Greg Dent: 00:21:04

estate brokerages, are so struggling so much with their

Greg Dent: 00:21:08

compliance. And I hope that by recording this and recording

Greg Dent: 00:21:11

this these thoughts, I'm able to kind of bridge that gap.

Greg Dent: 00:21:17

Certainly get really trusted. I we believe that there is a

Greg Dent: 00:21:22

future where real estate brokerages across the country

Greg Dent: 00:21:24

are well equipped to fulfill their FINTRAC obligations. And

Greg Dent: 00:21:27

when I think about the real estate brokerages that have

Greg Dent: 00:21:29

signed on to our FINRA Express program, I feel good about

Greg Dent: 00:21:33

knowing that their agents are getting a really high quality

Greg Dent: 00:21:36

AML, CTF training, their brokerages are getting high

Greg Dent: 00:21:39

quality policy and procedure manuals and their brokerages are

Greg Dent: 00:21:43

ready for an effectiveness review, or, more importantly,

Greg Dent: 00:21:47

for a fin track examination. But probably just as importantly,

Greg Dent: 00:21:51

I'm very proud to say that our brokerages are actually seeing

Greg Dent: 00:21:57

an increase in activities where they should be filing systems,

Greg Dent: 00:22:02

transaction reports, and they're they're noting that, and they're

Greg Dent: 00:22:04

wanting to file them, and they're understanding that

Greg Dent: 00:22:06

that's actually really an important part of their fin

Greg Dent: 00:22:09

track obligations is just paying attention and wanting to file

Greg Dent: 00:22:13

those. And we're seeing that expressed in the brokerages who

Greg Dent: 00:22:16

we're working with on a regular basis. So I believe that the

Greg Dent: 00:22:21

real estate sector one day will be in a better position. And I

Greg Dent: 00:22:24

think that certainly where I think really trusted is making a

Greg Dent: 00:22:28

dent. That's where it is right now is we're able to help those

Greg Dent: 00:22:31

brokerages better understand their fin track obligations and

Greg Dent: 00:22:35

better position them to be fulfilling their fin track

Greg Dent: 00:22:37

obligations. So I hope today's podcast as different as it's

Greg Dent: 00:22:40

been, just to listen to me for 25 minutes has been helpful, and

Greg Dent: 00:22:44

I do hope that you'll continue to join us on the KYC pod as we

Greg Dent: 00:22:49

have more guests and our talk about other topics related to

Greg Dent: 00:22:52

FINTRAC and anti money laundering and compliance

Greg Dent: 00:22:55

overall. Have a wonderful day. You.