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NAFCU Director of Regulatory Affairs Ann Kossachev and Regulatory Affairs Counsel Kaley Schafer met yesterday with members of the Financial Crimes Enforcement Network's (FinCEN) Office of Regulatory Policy to discuss issues related to S. 2155 implementation and the Bank Secrecy Act/anti-money laundering (BSA/AML) regime.

During Wednesday's meeting with staff in FinCEN's Office of Regulatory Policy, NAFCU shared credit union concerns regarding the implementation of some S. 2155 provisions: Section 213 (the MOBILE Act) and Section 303 (the Senior Safe Act). NAFCU has previously met with the CFPB and the NCUA to discuss the Senior Safe Act and credit unions' efforts to prevent elder financial abuse.

Additionally, the group discussed removing redundant fields on suspicious activity reports (SARs) and the use of a modified, shortened SAR in certain circumstances. NAFCU has previously raised concerns about the regulatory burden presented by FinCEN's rules on collecting SARs, and has also addressed the currency transaction reporting process. The association also discussed recent and upcoming guidance related to hemp banking.

Also discussed was the agency's efforts to promote BSA/AML innovation, as well as the BSA Value project. NAFCU earlier this year offered recommendations to strengthen the information sharing between government agencies, law enforcement and financial institutions through FinCEN's 314(a) program.

There are several BSA/AML reform bills being considered in both chambers of Congress. NAFCU has previously shared its support of Rep. Carolyn Maloney's, D - N.Y.,  Corporate Transparency Act (H.R. 2513) that would would help financial institutions comply with the new customer due diligence rule by requiring companies to disclose their true "beneficial owners" to FinCEN.

NAFCU has been active in seeking BSA/AML improvements and relief for credit unions.  A NAFCU witness has previously testified on the need for BSA/AML reforms, and the association is supportive of introduced legislation that would provide some relief to credit unions by raising certain thresholds, including for and SARs. 

The association will continue to advocate to reduce credit unions' regulatory burden and work with FinCEN on these issues.