WASHINGTON–CUNA said it plans to file a comment letter with the Financial Crimes Enforcement Network (FinCEN) regarding a proposed no-action letter process.
FinCEN earlier published an Advanced Notice of Proposed Rulemaking (ANPR) following a move by Congress requiring FinCEN to take action on no-action letters. In 2021 FinCEN recommended a process be established for no-action letters, and the ANPR is the first step, according to CUNA Director of Advocacy and Counsel Elizabeth Sullivan.
The CUNA letter will be supportive of the proposal, especially if a cross-regulator process is being considered, according to Sullivan. “We believe it will enhance consistency, which is the biggest credit union complaint,” Sullivan said.
The CUNA letter will outline a suggested process that would prioritize no action
letters’ usefulness as a compliance tool for the entire sector, Sullivan added.
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