Removing Barriers Blog

Comment Letter Seeks More Time for Industry to Respond to FinCEN Request
Posted January 08, 2016 by CUNA Advocacy

Together with other industry trade groups, we are asking FinCEN to allow more time for the industry to respond to a request for information regarding Customer Due Diligence Requirements for Financial Institutions.

In August 2014, FinCEN issued a proposed rule to amend existing Bank Secrecy Act (BSA) regulations regarding customer due diligence (CDD) requirements for credit unions, banks, and other related entities. The CDD Proposal would also impose a new requirement under the BSA to identify the beneficial owners of legal entity customers.

In December 2015, FinCEN made available documents related to the regulatory impact of the 2014 proposal, and is requesting information from the public regarding those documents. As described in today’s letter, we are requesting that FinCEN allow adequate time for the “development and provision of the thorough and accurate information that FinCEN needs and good policymaking requires.” Therefore, we ask that FinCEN extend the deadline—which is set to close January 25—until at least March 25.

We are seeking your input on the request for information. Please visit our resource page for additional information and to provide us with your comments.