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NAFCU supports the Financial Crimes Enforcement Network's proposal to amend the definitions of "funds transfer" and "transmittal of funds" under Bank Secrecy Act regulations because it would lead to greater consistency in the regulatory process, NAFCU's Tessema Tefferi wrote Friday.

FinCEN's proposed technical changes are in response to the Dodd-Frank Act's amendments to the Electronic Fund Transfer Act creating new protections for remittance transfers. The proposed changes would maintain the current scope of transactions covered by the BSA recordkeeping and travel rules, including international wire transfers and cash-based transmittals of funds sent through money transmitters.

In other comments, Tefferi, NAFCU's senior regulatory affairs counsel, told FinCEN in Friday's comment letter that the association agrees the Dodd-Frank Act's changes to remittance transfers are necessary in order to ensure consistency between the BSA and FinCEN's implementing regulations."It would also provide clarity to credit unions that the transactions in question remain subject to the ‘travel rule' and ‘recordkeeping rule,'" Tefferi wrote.

For more about FinCEN's proposed rule, see the Dec. 17 NAFCU Compliance Blog post.

• Comment letter