WASHINGTON—CUNA has sent a letter to FinCEN regarding the agency’s proposed rule regarding anti-money Laundering (AML) and suspicious activity report (SAR) filing requirements for registered investment advisers.
Luke Martone, CUNA senior director of advocacy and counsel, said that while CUNA does not have major issues with the requirements, it is concerned that they could add unnecessary regulatory burden to credit unions.
“We are concerned with situations where an investment advisor is affiliated with a financial institution, or one of its subsidiaries, and from these rules there could be risk of duplication of efforts by both (the credit union and the subsidiary),” said Martone, who signed the letter. “We asked FinCEN to review its proposal to eliminate any unnecessary duplication of efforts among financial institutions.”
Martone said that CUNA also reiterated concerns over CUs’ ability to comply with BSA and AML requirements when different regulators and examiners interpret BSA and AML guidance differently.
“That can make it difficult for credit unions to satisfy examiners and plan accordingly,” said Martone, emphasizing the need for greater regulatory and examination consistency among different regulators—including NCUA, state regulators, and FinCEN. “We would like FinCEN to look closely at this issue to see if anything can be done.”