On August 13th, the Financial Crimes Enforcement Network ("FinCEN") issued a Ruling to clarify the requirements under FinCEN's regulations for loan and finance companies that are subsidiaries of financial institutions subject to the same regulations applicable to the parent financial institution and examinations of a Federal functional regulator for compliance with the anti-money laundering and counter-terrorist financing obligations under the laws generally known as the Bank Secrecy Act. FinCEN has determined that a loan or finance company that: (1) is a subsidiary of a financial institution subject to these regulations, including at least anti-money laundering program ("AML") and suspicious activity reporting ("SAR") requirements; (2) is required to comply with the AML and SAR regulations applicable to the parent financial institution; and (3) is subject to examination by the Federal functional regulator of the parent financial institution, is deemed to comply with FinCEN's regulations.