Add’l efforts could help FinCEN collect most accurate cost estimates

October 14, 2020

CUNA submitted comments Tuesday on the Financial Crimes Enforcement Network’s (FinCEN) continued efforts to update burden estimates for Bank Secrecy Act regulations. The Paperwork Reduction Act (PRA) requires agencies to estimate the burdens their regulations impose on regulated industries.

“CUNA supports FinCEN’s efforts to update these PRA burden estimates in order to more accurately understand the regulatory compliance costs to financial institutions,” the letter reads. “We also agree that the identify verification, list consultation and recordkeeping burdens are relevant for accurately calculating the true costs of complying with the Customer Identification Program (CIP) regulations.”

The letter also notes that CUNA believes this PRA update can help FinCEN strike the right balance between the costs imposed on leanly staffed and primarily locally oriented credit unions and the benefits that the federal government and law enforcement gain from the regulation’s requirement.

“Prior to adopting final estimates, FinCEN would benefit from asking financial institutions to complete a voluntary survey measuring the hourly and monetary costs of compliance with the CIP rule, and can engage with industry groups like CUNA to assist by encouraging member participation,” the letter reads. “These efforts, beyond this PRA notice, would help FinCEN collect the broadest and most accurate cost estimate possible.”