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NAFCU offers feedback on interagency BSA/AML risk management guidance
NAFCU Senior Regulatory Affairs Counsel Kaley Schafer wrote to the NCUA Thursday to offer comments on an interagency request for information (RFI) seeking feedback on whether or not the principles included in interagency supervisory guidance on model risk management (MRMG) effectively support compliance with Bank Secrecy Act (BSA)/anti-money laundering (AML) requirements.
In addition to the NCUA, the interagency RFI was issued by the Office of the Comptroller of the Currency (OCC), Federal Reserve, Federal Deposit Insurance Corporation (FDIC) and Financial Crimes Enforcement Network (FinCEN).
In the letter, Schafer requested the NCUA minimize examination burdens by not making requests for model validations and urged the NCUA to bear in mind the difficulties in validating models when making requests to do so during examinations.
Additionally, Schafer encouraged the interagency group to consult the Federal Financial Institutions Examination Council's (FFIEC) examination reports and supervisory information through regulator information sharing to assess MRMG changes.
Read Schafer’s full letter. NAFCU will continue to keep credit unions up-to-date on this topic via NAFCU Today.