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.