The Treasury’s Financial Crimes Enforcement Network (FinCEN) should continue to work with the financial services industry as any issues with implementation of its customer due diligence (CDD) rule arise, CUNA wrote Tuesday. CUNA sent a letter for the record of a House subcommittee hearing on the rule, which became effective last week.
“We urge this subcommittee to continue to encourage FinCEN to work with the industry on implementation issues as they arise. While the CDD Rule is already in effect, matters requiring clarification will undoubtedly continue to present themselves,” the letter reads. “In addition, we hope FinCEN continues its practice of providing timely responses to specific inquiries by credit unions and other affected financial institutions.”
CUNA noted that, while NCUA is the lead agency that will examine credit unions for compliance with the CDD rule, FinCEN should work closely together with NCUA “as examiners become more comfortable with the specific requirements of the rule.”
CUNA also expressed to the subcomittee its appreciation for FinCEN's responsiveness to the industry, including CUNA, for the past few years as the rule was finalized.
"FinCEN solicited input on the CDD Rule and directly addressed issues raised by the industry, including specific concerns and suggestions from CUNA and our member credit unions," the letter reads. "The guidance was released last month in the form of a Frequently Asked Questions document; we greatly appreciate such guidance ahead of the effective date, which is an uncommon practice among federal financial regulatory agencies.
CUNA believes this cooperation will be much more efficient and effective for the credit union system, as well as FinCEN and NCUA.