WASHINGTON (1/11/16)--A 30-day comment period, particularly one spanning the holidays and end-of-year period, is not long enough to generate meaningful feedback on the burden of costs associated with proposed changes to customer due diligence rules, says the Credit Union National Association (CUNA) and other trade organizations.

In a letter sent Friday to the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN), CUNA and the other organizations requested an extension of the comment period to end no earlier than March 25. Comments are currently due Jan. 25.

FinCEN recently asked stakeholders to share their cost projection for the rule it proposed in August 2014, which would amend existing Bank Secrecy Act (BSA) requirementsfor credit unions and others, and impose a new requirement to identify the beneficial owners of legal entity customers, with certain exemptions.

FinCEN determined that the proposal’s implementation and compliance may exceed $100 million annually, which required a Regulatory Impact Assessment (RIA) to be issued. A separate Initial Regulatory Flexibility Analysis (IRFA) was issued to evaluate the proposal’s impact on entities with assets of $550 million of less.

“Given the complexity of the task and the importance to the economy of a carefully calibrated rule, stakeholders should be given significantly more than 30 days to comment,” the letter reads. “Indeed, if FinCEN seeks thoughtful and thorough feedback, sufficient time is needed to permit those affected to consider each of the different elements identified as benefits and costs and to develop data and provide feedback.

“This is especially critical since our initial review suggests that some of the analyses may be based on limited information and questionable assumptions,” the letter adds. “With adequate time we believe that the quality of information available to FinCEN can be significantly enhanced, resulting in more optimal policymaking.”

The organizations also point out that the elements necessary for a thoughtful comment on cost-benefit analysis require access to information technology resources, resources that are often occupied with a number of year-end accounting procedures and other projects.

Regardlness of an extension, CUNA seeks input on the request, and will accept comments until Jan. 13. 

In addition to CUNA, the letter was signed by the American Bankers Association, Independent Community Bankers of America and the National Association of Federal Credit Unions.