Private Money Lending--Requests Made by my Bank

[John Jacobs]

Hello BP,

I have been a very active private money lender since 2014. I have a single member LLC (me as the sole member) that lends only to real estate investors. That is I do not lend to owner occupants. I only lend to businesses (i.e. LLCs and Incs.) who are renovating the property for sale or to keep as a buy and hold rental. I only lend in states in which I do not have to have a license in order to lend. My lending entity (i.e. my LLC) has a bank account at a national bank. I have been making loans out of this bank account since 2014. For all loans, amongst other things, I have a recorded Mortgage/Deed of Trust, Promissory Note, and Personal Guarantee in place.

Yesterday, out of nowhere, my bank reached out to me and asked me if my business was regulated. I said no. I explained to them the nature of my business. The bank is now requiring the following two things from me: (1) That there be an Anti-Money Laundering (AML) Program in place. (2) That I have a Third Party Audit conducted of my "company" which as stated is a single member LLC.

Does anyone have any experience with the above requests?  I am considering moving my money to another bank.  On the other hand I might consider complying but frankly I don't know how to get the two aforementioned requests accomplished.

Thoughts?

JJ