Today, CUNA submitted comments to the Financial
Crimes Enforcement Network (FinCEN) in response to their update, without
change, of certain Bank Secrecy Act (BSA)
estimates of the industry burden imposed by customer identification program
(CIP) regulations. CUNA expressed support for FinCEN’s continued efforts to
update these PRA burden estimates for BSA regulations to more accurately
understand the regulatory compliance costs to financial institutions like
credit unions.
CUNA also encouraged FinCEN,
prior to adopting final estimates, to consider issuing a voluntary industry
survey to get a more precise measure of the hourly and monetary costs of
confirming the identity of customers, establishing CIP recordkeeping processes
and consulting government terrorist and terrorism watch lists.