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Anti-Money Laundering Program: New Challenges for Nonbank Mortgage Lenders and Originators 2012

Speaker(s): Beth Moskow-Schnoll, Richard J. Andreano, Jr.
Recorded on: Mar. 21, 2012
PLI Program #: 38942

Beth Moskow-Schnoll is a partner in the Litigation Department and a member of the White Collar/Investigations, Health Care, and Consumer Financial Services Groups. She concentrates her practice on white-collar litigation, regulatory enforcement and compliance, and complex civil litigation, with an emphasis on banking and other financial services litigation.

As lead counsel, Ms. Moskow-Schnoll has tried to verdict dozens of cases in federal district court. She also has successfully briefed and argued multiple cases before the Third Circuit Court of Appeals. She has convinced the government to decline prosecution of clients in matters involving allegations of health care fraud, financial fraud, and environmental crimes, and has conducted internal investigations for clients in the health care, petroleum, and other industries. 

Ms. Moskow-Schnoll has advised and counseled clients on compliance programs and in responding to government investigative and enforcement actions. She has experience with export commodity classifications, jurisdiction requests, and preparation of license applications for submission to the Office of Foreign Asset Control, and has provided day-to-day counseling on licensing requirements and strategy. In the civil arena, Ms. Moskow-Schnoll represents major financial institutions, bringing actions against fraudulent debt relief companies and defending against consumer financial services lawsuits asserting a wide variety of claims.

Before joining Ballard Spahr, Ms. Moskow-Schnoll served for more than a decade as a federal prosecutor with the U.S. Attorney's Office for the District of Delaware, including five years as the office's Criminal Healthcare Fraud Coordinator. As an AUSA, Ms. Moskow-Schnoll investigated and prosecuted financial and health care fraud, including bank and credit card fraud, money laundering, asset forfeiture, and tax offenses. Among her notable achievements was the successful prosecution of a major pharmaceutical company that resulted in a criminal conviction and the largest monetary penalty in the history of the District of Delaware.

Judicial Clerkships
Hon. Alicemarie H. Stotler, U.S. District Court for the Central District of California


  • Federal Bar Association, Executive Committee and New Members Chair
  • American Bar Association
  • Delaware State Bar Association
  • Richard S. Rodney Inn of Court
  • American Health Lawyers Association
  • Rutgers School of Law-Camden, Adjunct Professor, "Healthcare Fraud and Abuse"


  • Stanford Law School (J.D. 1986)
  • University of Pennsylvania (B.A. 1982, summa cum laude)
  • Member, Phi Beta Kappa


  • Delaware
  • Pennsylvania
  • U.S. District Court for the Eastern District of Pennsylvania
  • U.S. District Court for the District of Delaware
  • U.S. Court of Appeals for the Third Circuit

Richard J. Andreano, Jr., is a partner in the Business and Finance Department, Practice Leader of the Mortgage Banking Group, and a member of the Consumer Financial Services and Privacy and Data Security Groups. He has devoted more than 25 years of practice to financial services, mortgage banking, and consumer finance law.

Mr. Andreano advises lenders, brokers, home builders, title companies, real estate professionals, and other settlement providers on regulatory compliance and transactional matters, Federal Housing Administration (FHA) issues, and administrative enforcement actions and investigations. He also works with litigation counsel on devising strategies for defense of class action and other lawsuits involving regulatory claims.

Mr. Andreano counsels settlement service providers on issues concerning the Dodd-Frank Wall Street Reform and Consumer Protection Act, Real Estate Settlement Procedures Act (RESPA), Truth in Lending Act (TILA), Equal Credit Opportunity Act (ECOA), Fair Housing Act, Fair Credit Reporting Act (including FACTA), Home Mortgage Disclosure Act (HMDA), and Gramm-Leach-Bliley Act. He assists clients with regulatory issues relating to loan originator compensation, disclosures, servicing, the liquidation of distressed loan portfolios, affiliated business and service arrangements, and incentive arrangements. Mr. Andreano previously served as an analyst for the National Association of Securities Dealers.

Mr. Andreano is Editor-in-Chief of Mortgage Finance Regulation Answer Book 2011-2012, published by the Practising Law Institute; author of its chapters on the Dodd-Frank Wall Street Reform and Consumer Protection Act, the Home Mortgage Disclosure Act, and the Real Estate Settlement Procedures Act; and co-author of its Equal Credit Opportunity Act and Truth in Lending Act chapters.

Representative Matters

  • Providing legal counsel in review of a servicer's compliance with an OCC Consent Order related to foreclosure practices
  • Aided in the creation, revision, and implementation of loan originator compensation policies
  • Aided in the development and operations of fee-for-services, joint venture, and consumer incentive arrangements consistent with RESPA, FHA, and other regulatory requirements 
  • Aided in the creation and implementation of policies and procedures in connection with the Home Affordable Mortgage Program (HAMP) and related programs
  • Aided in the creation and implementation of policies and procedures to comply with major RESPA rule changes effective January 2010 
  • Aided in the creation and implementation of policies and procedures to comply with various FCRA requirements, including the risk-based pricing rules 
  • Aided in the creation and implementation of policies and procedures to comply with changes to the FHA loan insurance program 
  • Aided in the creation and implementation of policies and procedures to comply with TILA requirements added by the Mortgage Disclosure Improvement Act 
  • Aided in the creation and implementation of policies and procedures to comply with major TILA rule changes effective October 2009 
  • Aided in the analysis of HMDA data to give lenders the ability to respond to government, press, and community group inquiries


  • American Bar Association
  • District of Columbia Bar Association
  • Virginia Bar Association


  • George Washington University Law School (J.D. 1983, with honors)
  • State University of New York at Oneonta (B.A. 1980, with honors)