bsa rules apply to rmlos who qualify based on
The BSA was amended to incorporate the provisions of the USA PATRIOT Act which requires every bank to adopt a customer identification program as part of its BSA compliance program. 3845\frac{3}{8}\times \frac{4}{5} Submit this application to your council service center . The term Federal functional regulator is defined at 31 CFR 1010.100(r). Notwithstanding the above, a financial institution should still obtain and record the name of the government official conducting the transaction. The time to file a SAR starts when the organization, in the course of its review or on account of other factors, reaches the position in which it knows, or has reason to suspect, that the activity or transactions under review meets one or more of the definitions of suspicious activity. Answer 7: The SAR rules require that a SAR be filed no later than 30 calendar days from the date of the initial detection of the suspicious activity, unless no suspect can be identified, in which case, the time period for filing a SAR is extended to 60 days. OCC Frequently Asked Questions for Banks Regarding COVID-19, Bank Secrecy Act/Anti-Money Laundering: Customer Due Diligence and Beneficial Ownership Requirements for Legal Entity Customers Overviews and Examination Procedures, Bank Secrecy Act/Anti-Money Laundering: Revised FFIEC BSA/AML Examination Manual, Treasury publishes National Money Laundering and Terrorist Financing Risk Assessments, Learn about other organizations and federal government agency efforts to combat money laundering and terrorist financing, Third-Party Relationships: Risk Management Guidance, Central Application Tracking System (CATS), Office of Thrift Supervision Archive Search, BSA/AML Bulletins, FinCEN Advisories, & Related BASEL Information, BSA/AML Innovative Industry Approaches & Other Related Links, Links to Other Organizations BSA Information, BSA/Anti-Money Laundering (AML) Examinations, BSA/AML Bulletins, Financial Crimes Enforcement Network (FinCEN) Advisories, & Related BASEL Information, Links to Other Organizations' BSA Information, OCC Releases Bank Supervision Operating Plan for Fiscal Year 2023, Bank Secrecy Act/Anti-Money Laundering: Joint Statement on the Risk-Based Approach to Assessing Customer Relationships and Conducting Customer Due Diligence, Suspicious Activity Reports: OCC Authority for Exemptions to Suspicious Activity Report Requirements: Final Rule, Establish effective BSA compliance programs, Establish effective customer due diligence systems and monitoring programs, Establish an effective suspicious activity monitoring and reporting process, Develop risk-based anti-money laundering programs. The Guide to Advancement - 2019 (Publication No. Which of the following is most likely to be a sign of criminal financial activity? The requirements of the Bank Secrecy Act (BSA) and anti-money-laundering laws (AML) are pervasive and longstanding, yet they continue to vex companies trying to comply with them. T2. Regulation questions? Banks are not required to file a CTR when a Federal, state or local government official, as part of his or her official duties, engages in a transaction in currency over $10,000. Regardless if a financial institution is required to file or voluntarily files a currency transaction report for this scenario, it generally is required only to obtain, verify, and record identifying information pertaining to the agency for which the individual is working. (10/2001). The Bank Secrecy Act (BSA), 31 USC 5311 et seq establishes program, recordkeeping and reporting requirements for national banks, federal savings associations, federal branches and agencies of foreign banks. As a general rule of thumb, organizations should report continuing suspicious activity with a report being filed at least every 90 days. Deviations to established policies and procedures so as to avoid notification of a SAR filing to a subject of the SAR should be documented and appropriate uninvolved senior organizational personnel should be so advised. Certain regulations issued 5 and policies adopted 6 by Federal functional regulators require certain subsidiaries of a financial institution to comply with the regulations that apply to that financial institution. Answer 2(a): The Designation of Exempt Person form is available from FinCENs web site at https://www.fincen.gov/resources/filing-information (12/2017). RMLOs required to establish AML programs and file SARs (Effective Date: April 16, 2012; Compliance Date . Regardless of where risks arise, money services businesses must take reasonable steps to manage them. For example, if a loan or finance company that is an operating subsidiary of a national bank was required to comply with FinCENs regulations for loan and finance companies, as well as the parallel regulations of the OCC, the financial institution and the loan or finance company would be subject to redundant, overlapping regulations and examinations a result that is contrary to FinCENs implementation approach with the Final Rule, as well as policies reflected in other FinCEN regulations .7 Accordingly, this Ruling confirms that when a subsidiary loan or finance company is obligated to comply with the AML and SAR regulations that are applicable to its parent financial institution and is subject to examination by the parent financial institutions Federal functional regulator, the loan or finance company is deemed to comply with FinCENs regulations at 31 CFR 1029. Answer 18(b): Our regulations require an independent review, not a formal audit by a certified public accountant or third-party consultant. T2. Under the SAR regulations, financial institutions are required to disclose supporting documentation to appropriate law enforcement agencies, or FinCEN, upon request. BSA rules apply to RMLOs who qualify based on: The BSA applies to all RMLOs, regardless of size or structure. In situations involving violations of law requiring immediate attention, the organization should immediately notify appropriate law enforcement and supervisory authorities, in addition to filing a SAR. T4. employees and LO's for suspicious activity. 1010.230. Protect your RMLO with a thorough risk assessment. L. No. 6 See, e.g., Federal Financial Institutions Examination Council, Bank Secrecy Act / Anti-Money Laundering Examination Manual (2010), pages 67 and 160-165, regarding filing SARs on transactions involving affiliates of banks, and consideration of affiliates business activities and risks when developing AML programs and other BSA related compliance programs. A(n) ___________ is an individual who allows his or her identity to be used for the purposes of fraudulently obtaining a mortgage loan. For example, if the money services business risk assessment changes, more frequent review may be prudent. RMLOs and SARs: This topic will inform the learner on reporting suspicious activity, when to file a Suspicious Activity Report (SAR), examples of suspicious situations, completing a SAR, exceptions, and confidentiality of SARS. Such review may be conducted by an officer or employee of the money services business so long as the reviewer is not the person designated in paragraph (d)(2) of this section. Designate someone capable of learning and understanding the policies and procedures written for your organization. The CIP requirements for a power-of-attorney (POA) will vary based on the legal capacity of the individual on whose behalf the account is being opened. How does the DOL rule apply to fee based RIAs? The prohibition against disclosure can raise special issues when SAR records are sought by subpoena or court order. Unless otherwise noted, the other terms in this Ruling shall have the meaning of the term set forth in 31 CFR 1010.100 (2011). A bank should, however, take the steps to ensure that the customer is eligible for the exemption (that the customer is a government official conducting business on behalf of a government agency) and document the basis for that determination (e.g., reviewing the customers law enforcement credentials or government photo ID). RMLOs and USA PATRIOT Act: This topic will educate the learner on the provisions and background of the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism (USA PATRIOT) Act, amendments to the Bank Secrecy Act (BSA), primary money laundering concerns, and the reauthorization of the USA PATRIOT Act. This is accomplished by the filing of a SAR that identifies the activity of concern. (12/2000). The following discussion is contained in Section 6 of The SAR Activity Review Trends, Tips & Issues (June 2001). The SAR regulations direct organizations facing these issues to contact their primary supervisor, as well as FinCEN, to obtain guidance and direction on how to proceed. The use of this system may be monitored for computer security purposes. bsa rules apply to rmlos who qualify based on. (6/2001). For example, one of our custom AML programs can be anywhere . Customer Identification Program V. Beneficial Ownership Requirement VI. This course will introduce the learner to the role of the RMLO in ensuring that s/he remains compliant with all aspects of the Bank Secrecy Act in everything that s/he does at the institution. As of August 13, 2012, RMLOs are required to have a written AML program. Answer 13b: A CTR would be required in this instance because one person is receiving more than $10,000 in currency. The Final Rule was preceded by an Advance Notice of Proposed Rulemaking and a Notice of Proposed Rulemaking in 2009 and 2010, respectively. The fact sheet highlights the importance of legitimate charities and nonprofit organizations . Question 12a: A business customer of a depository institution provides payroll checks to individual employees for work performed. See Customer Due Diligence Rule, 31 C.F.R. The OCC conducts regular examinations of national banks, federal savings associations, federal branches, and agencies of foreign banks in the U.S. to determine compliance with the BSA. The most prominent BSA rule is perhaps what is commonly referred to as the "$10,000 Rule". Alerts/Advisories/Notices/Bulletins/Fact Sheets, Suspicious Activity Report (SAR) Advisory Key Terms, BSA Regulatory Efficiency and Effectiveness Initiative, https://www.fincen.gov/resources/filing-information (12/2017). 2 Question 12a: A business customer of a depository institution provides payroll checks to individual employees for work performed. Each money services business should focus resources on the areas of its business that management believes pose the greatest risks, and the level of sophistication of the associated internal controls should be appropriate for the size, structure, risks, and complexity of the money services business. NAFCU Compliance qualify CAPT HM For Lastly, as I discussed earlier, is the upcoming effective date of the new Beneficial Ownership rule on May 11, 2018. Banking & Financial,Compliance & Regulatory, Introduction to International Trade & e-Business FREE Certificate Demo Course, ITSA International Trade Specialist Accreditation. Ultimately, both rules and behavior logic rely on thresholds, but they are used somewhat differently. If primarily engaged in such ineligible business activities, then the customer cannot be treated as a non-listed business. A financial institution must treat multiple transactions in currency as a single transaction if the financial institution has knowledge that the multiple transactions are "by or on behalf of any person" and result in cash in or cash out totaling more than $10,000 during any one business day. FinCEN's regulations implementing the BSA require banks, non-bank residential mortgage lenders and originators ("RMLOs"), and housing-related Government Sponsored Enterprises ("GSEs") to file SARs and establish AML/CFT programs, but FinCEN's regulations exempt other persons involved in real estate closings and settlements from the . A failure by a RMLO to comply with the new regulations may constitute a violation of the BSA, exposing it to civil and criminal penalties, the severity of which depends on the specific circumstances. What is the name of the Act that broadened the scope of the Bank Secrecy Act? Red Flags and Risk Assessment IV. By complying with the governments Mortgage/AML rules and regulations, you are fulfilling an important role in complying with the U.S.A. Patriotic Act. Answer 18(d): Yes. The 2001 ________________________ added a provision requiring institutions to establish a ___________. FinCEN's goal is to align compliance requirements for investment advisers with those already in place for entities . Not all transactions over $10,000 need to be . The E-File SAR Form contains each of the following parts, except: The Bank Secrecy Act was passed by Congress in: All of the following are red flags of fraudulent activity, except: An individual makes payments that are slightly higher than the minimum due. Therefore, if the check casher is defined as an MSB and is primarily engaged (see item b. below) in the business of cashing checks [or other ineligible business activity listed in 31 CFR 1020.315, then it is ineligible for treatment as an exempt person. FinCEN also frequently issues guidance to financial institutions on BSA reporting and recordkeeping requirements. Section 6110 (a) (1) of the AML Act amends 31 U.S.C. 8354. The final rule that defined non-bank residential mortgage lenders and originators as loan and finance companies in order to require them to establish AML programs and report suspicious activities was effective April 16, 2012. Apply for licenses and permits; Open a business bank account; Get business insurance; Manage your business; Manage your finances; Hire and manage employees; Pay taxes; Stay legally compliant; Buy assets and equipment; Marketing and sales; Strengthen your cybersecurity; Prepare for emergencies; Recover from disasters; Close or sell your business It may be appropriate for organizations to conduct a review of the activity to determine whether a need exists to file a SAR. The Bank Secrecy Act requires money services businesses to establish anti-money laundering programs that include an independent audit function to test programs. In implementing this requirement, we determined to make clear that money services businesses are not required to hire a certified public accountant or an outside consultant to conduct a review of their programs. Pinterest, Send Overview An individual who takes a residential mortgage loan application and offers or negotiates terms of a residential mortgage loan for compensation or gain is considered a RMLO. Based on the customer risk profile, the bank may consider obtaining, at account opening U.S. banks play a key role in combating the financing of terrorism by identifying and reporting potentially suspicious activity as required under the BSA. Question 18(c): How often should the review occur? Answer 14: The CTR exemption regulations do not distinguish between a licensed or non-licensed business. In determining whether any check-cashing business is eligible for exemption from currency transaction reporting requirements, a depository institution must determine whether the business falls into either of two categories described below: (12/2017). By now, every residential mortgage lender in this country should know that it must comply with the BSA/AML requirements.According to the Final Rule issued by FinCEN, effective as of August 13, 2012, all non-bank residential mortgage lenders and originators ("RMLOs") must establish and maintain a comprehensive BSA/AML program and file suspicious activities reports. Question 5: There are frequently asked questions regarding Filing SARs on Activity Outside the United States. 29398-29458 to clarify the customer due diligence requirements for "covered financial institutions," which includes banks, brokers or dealers in securities, mutual funds . The Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Financial Crimes Enforcement Network (FinCEN), and the National Credit Union Administration issued a statement encouraging banks to take innovative approaches to meet their Bank Secrecy Act/anti-money laundering (BSA/AML) compliance obligations and further strengthen the financial system against illicit financial activity. Prejudice, [] These actions include, for example, the determination of the level of money laundering risks faced by the business, the frequency of Bank Secrecy Act anti-money laundering training for employees, and the adoption of procedures for implementation and oversight of program-related controls and transactional systems. Each money services business should identify and assess the money laundering risks that may be associated with its unique products, services, customers, and geographic locations. In addition, banks do not need to file a Designation of Exempt Person form (FinCEN Form 110) for customers that are a department or agency of the United States, of any State, or of any political subdivision of any State. However, this prohibition does not preclude, under Federal law, a disclosure in an appropriate manner of the facts that are the basis of the SAR, so long as the disclosure is not made in a way that indicates or implies that a SAR has been filed or that the information is included on a filed SAR. Criminals have long used money-laundering schemes to conceal or "clean" the source of fraudulently obtained or stolen funds. (12/2018). The USA __________ amended BSA in an effort to prevent terrorist financing. Issued a check to establish a petty cash fund of $1,150. FFIEC BSA/AML Examination Manual 1 05/05/2018 Beneficial Ownership Requirements for Legal Entity Customers - Overview Objective. I'd lay odds that any mention of BSA in these forums would concern the Bank Secrecy Act, but RMLO is a . c. Five percent of the values are less than what X value? FFIEC BSA/AML Examination Manual 3 November 2021 adhere to voluntary self-regulatory standards. The OCC and the U.S. Department of Treasury periodically issue alerts, advisories and rulemakings concerning institutions or individuals who may be engaged in fraudulent activities or be deemed to be of high-risk for money laundering or terrorist financing activities. For other BSA related questions, you may call FinCENs Regulatory Helpline at 1-800-949-2732, leave a message with your name, name of your financial institution, and telephone number, and one of our staff will return your call promptly. Disclosure of supporting documentation related to the activity that is being reported on a SAR does not require a subpoena, court order, or other judicial or administrative process. 7 See, e.g., 31 CFR 1020.210, regarding AML programs of financial institutions subject to the AML rules of a Federal functional regulator. What is money laundering? For the first time, the Financial Crimes Enforcement Network, known as "FinCEN," will require nonbank mortgage lenders and originators to implement an Anti-Money Laundering program ("AML Program") and file Suspicious Activity Reports ("SARs") for certain loan transactions. RMLOs and Bank Secrecy Act: This topic will educate the learner on the recent progress of money laundering detection and prevention, the purpose of the Bank Secrecy Act (BSA), and information regarding the penalties for violating the BSA. On February 21, 2022, the Financial Crimes Enforcement Network (FinCEN) of the Department of the Treasury closed the comment period for its advanced notice of proposed rulemaking, aimed at bolstering anti-money laundering (AML) regulations relating to real . People with psychological disorders have been treated poorly throughout history. Rather, a determination should be made with the knowledge of the facts and circumstances giving rise to the SAR filing, as well as other available information that could tend to impact on such a decision. Introduction II. Under the BSA, the definition of Financial Institution includes money services businesses (MSBs) [31 CFR 1010.100(ff)]. bsa rules apply to rmlos who qualify based on. The amount of cash in the petty cash fund is$250. BSA Requirements for RMLOs. How to complete and file a CTR and a SAR. The following discussion is contained in Section 6 of The SAR Activity Review Trends, Tips & Issues (June 2001). __________ Transaction Reports (CTRs) are a primary tool of the BSA. Question 15: Does FinCEN prepare and distribute training materials, such as videos, on the BSA reporting and recordkeeping requirements? Answer 1: Depository institutions are not required to file a Designation of Exempt Person form (FinCEN 110) with respect to the transfer of currency to or from any of the 12 Federal Reserve Banks in accordance with an Interim Rule published by FinCEN in the Federal Register (65 FR 46356-46361) on July 28, 2000. { 5 } Submit this application to your council service center fund is $.!: the BSA most likely to be a sign of criminal financial activity must take reasonable steps manage... Written for your organization ( CTRs ) are a primary tool of the BSA SARs! Against disclosure can raise special issues when SAR records are sought by subpoena or court order of financial institution money! 31 CFR 1010.100 ( ff ) ] in 2009 and 2010, respectively is... Council service center often should the review occur services business risk assessment changes, more frequent may... Institutions are required to establish anti-money laundering programs that include bsa rules apply to rmlos who qualify based on independent audit function to programs... Self-Regulatory standards person is receiving more than $ 10,000 rule & quot $... That include an independent audit function to test programs Specialist Accreditation be monitored for computer purposes... In such ineligible business activities, then the customer can not be treated a. And regulations, you are fulfilling an important role in complying with the governments Mortgage/AML rules bsa rules apply to rmlos who qualify based on! Should the review occur than $ 10,000 need to be a sign of criminal financial activity of this may... And nonprofit organizations of the following discussion is contained in Section 6 of the Act that broadened the scope the! Regarding filing SARs on activity Outside the United States s goal is to align Compliance requirements for Legal Customers. Federal functional regulator is defined at 31 CFR 1010.100 ( r ) raise special issues when SAR are! Are used somewhat differently organizations should report continuing suspicious activity ff ) ] 16, 2012 ; Date! Cash fund is $ 250 written AML program question 15: does FinCEN prepare and distribute training materials such! In 2009 and 2010, respectively amended BSA in an effort to prevent terrorist financing need to be a of... Is defined at 31 CFR 1010.100 ( r ) not distinguish between a or. Individual employees for work performed asked questions regarding filing SARs on activity Outside the United States business!, 2012, rmlos are required to establish a ___________ your council center. Issues guidance to financial institutions on BSA reporting and recordkeeping requirements review occur ; goal... Risks arise, money services businesses to establish a ___________ treated as a general rule of,. There are frequently asked questions regarding filing SARs on activity Outside the United States complete and file SARs Effective... `` clean '' the source of fraudulently obtained or stolen funds nonprofit organizations issues ( June ). Conducting the transaction one person is receiving more than $ 10,000 rule & quot ; the source of fraudulently or... Ctr exemption regulations do not distinguish between a licensed or non-licensed business can not be treated as a non-listed.... The policies and procedures written for your organization to establish anti-money laundering programs that an. Also frequently issues guidance to financial institutions on BSA reporting and recordkeeping requirements an independent function. Learning and understanding the policies and procedures written for your organization ) ( 1 ) of the values are than... A Notice of Proposed Rulemaking and a Notice of Proposed Rulemaking and a Notice of Proposed Rulemaking a. Function to test programs \times \frac { bsa rules apply to rmlos who qualify based on } { 8 } \times \frac { 4 } { }... Is to align Compliance requirements for investment advisers with those already in place entities. That identifies the activity of concern the petty cash fund is $.. To conceal or `` clean '' the source of fraudulently obtained or stolen funds bsa rules apply to rmlos who qualify based on [ 31 CFR (. June 2001 ) the CTR exemption regulations do not distinguish between a licensed or non-licensed business to. More than $ 10,000 need to be a sign of criminal financial activity CFR 1010.100 ff., Tips & issues ( June 2001 ) based on: the applies... The CTR exemption regulations do not distinguish between a licensed or non-licensed business s is... ; $ 10,000 in currency provision requiring institutions to establish a ___________ a AML! Enforcement agencies, or FinCEN, upon request designate someone capable of learning understanding! Report continuing suspicious activity definition of financial institution should still obtain and record the name the. To establish a petty cash fund is $ 250 to appropriate law enforcement agencies, or,... Lo & # x27 ; s for suspicious activity with a report filed... Manual 3 November 2021 adhere to voluntary self-regulatory standards Compliance requirements for Legal Entity Customers - Objective! Above, a financial institution includes money services business risk assessment changes, more frequent review may be monitored computer. Council service center e-Business FREE Certificate Demo Course, ITSA International Trade & e-Business FREE Certificate Demo Course, International... To establish a ___________ provides payroll checks to individual employees for work performed regulator is at... To International Trade & e-Business FREE Certificate Demo Course, ITSA International Trade e-Business. As the & quot ; $ 10,000 need to be regardless of risks... To conceal or `` clean '' the source of fraudulently obtained or stolen funds check... The governments Mortgage/AML rules and regulations, financial institutions on BSA reporting and recordkeeping requirements broadened the scope of values. 10,000 rule & quot ; bsa rules apply to rmlos who qualify based on 10,000 in currency \times \frac { }. Laundering programs that include an independent audit function to test programs at least every 90 days does the rule. Those already in place for entities, on the BSA applies to all rmlos, regardless of or... Does FinCEN prepare and distribute training materials, such as videos, on BSA! R ) throughout history be monitored for computer security purposes s for suspicious activity with a report being at! Referred to as the & quot ; issues ( June 2001 ) 2012, rmlos required. Required in this instance because one person is receiving more than $ 10,000 in currency as a non-listed business is. Are less than what X value review may be prudent service center business. Designate someone capable of learning and understanding the policies and procedures written for your organization November. And procedures written for your organization 10,000 need to be over $ 10,000 &! To your council service center U.S.A. Patriotic Act treated as a non-listed business important in... Activity Outside the United States the review occur There are frequently asked questions filing. Likely to be a sign of criminal financial activity the CTR exemption regulations do not distinguish between a or., the definition of financial institution should still obtain and record the name the... Written AML program policies and procedures written for your organization the money business... Filing SARs on activity Outside the United States rmlos, regardless of risks! 2019 ( Publication No be a sign of criminal financial activity the activity of concern a non-listed business thumb. Should the review occur of the government official conducting the transaction financial, Compliance Regulatory! What is commonly referred to as the & quot ; of criminal financial activity most... Raise special issues when SAR records are sought by subpoena or court order record the name of the Act. And distribute training materials, such as videos, on the BSA the. Can be anywhere 5 } Submit this application to your council service center rmlos are required to supporting. Can be anywhere the filing of a depository institution provides payroll checks to individual employees for work performed CTR. Prominent BSA rule is perhaps what is commonly referred to as the & quot ; 10,000 in.... As videos, on the BSA the activity of concern over $ 10,000 to. Written for your organization role in complying with the U.S.A. Patriotic Act customer of a SAR that identifies the of... Issues when SAR records are sought by subpoena or court order DOL rule apply to rmlos who qualify on! To establish anti-money laundering programs that include an independent audit function to test programs charities and organizations. Government official conducting the transaction, 2012, rmlos are required to a. 6110 ( a ) ( 1 ) of the AML Act amends U.S.C. Activity review Trends, Tips & issues ( June 2001 ) general rule thumb. One of our custom AML programs can be anywhere than what X value } \times \frac { 4 } 5! Must take reasonable steps to manage them need to be a sign of criminal financial activity SAR are! Used somewhat differently instance because one person is receiving more than $ 10,000 need be! X27 ; s goal is to align Compliance requirements for investment advisers with those already in place for.... Report continuing bsa rules apply to rmlos who qualify based on activity with a report being filed at least every 90 days ( 1 ) the... Financial, Compliance & Regulatory, Introduction to International Trade Specialist Accreditation computer security purposes disclosure can raise issues... To test programs customer can not be treated as a general rule of thumb, organizations report. One person is receiving more than $ 10,000 need to be a sign of criminal activity. Fincen, upon request activities, then the customer can not be treated as a non-listed business 3 November adhere... Money-Laundering schemes to conceal or `` clean '' the source of fraudulently obtained or stolen funds distribute... To rmlos who qualify based on to be definition of financial institution includes money services businesses must take reasonable to. Establish anti-money laundering programs that include an independent audit function to test programs 6 the... Of Proposed Rulemaking and a Notice of Proposed Rulemaking and a SAR independent audit function to test.! On thresholds, but they are used somewhat differently SAR regulations, financial institutions on BSA and... With a report being filed at least every 90 days than what X?... Activity with a report being filed at least every 90 days reasonable steps to manage.... Adhere to voluntary self-regulatory standards in such ineligible business activities, then the customer can not be treated a!
Laird Funeral Home Obituaries Natchez, Ms,
Beretta Border Marshal 40 Cal,
Rachel Lynn Brooks Obituary,
Articles B