Removing Barriers Blog

CUNA Responds to NCUA and FinCEN RFI on Risk Modeling in BSA/AML Compliance
Posted June 11, 2021 by CUNA Advocacy

CUNA filed comments with FinCEN and NCUA in response to an Interagency Request for Information regarding the use of a Model Risk Management Guidance (MRMG) in BSA/AML compliance. The Federal Reserve Board and OCC adopted the MRMG in 2011. The FDIC followed in 2017. To date, the NCUA has not adopted this guidance, and as such, the guidance does not explicitly apply to federally-insured credit unions. However, credit unions do use models in risk management as part of their BSA/AML compliance programs and the guidance does inform industry-wide products, services and processes. In April, the Federal Reserve Board, OCC, and FDIC issued a statement with NCUA and FinCEN clarifying that the MRMG represents guidance, not regulatory requirements. In its letters, CUNA discusses the role these models play in credit union BSA/AML compliance programs, the potential effects of changes to the MRMG on those programs, and it applauded the interagency statement as providing clarity for BSA/AML compliance expectations.