Participation in MLRS Proposed for All OCC-Supervised Banks

The OCC is seeking comments on proposed changes to its Bank Secrecy Act/Money Laundering Risk Assessment, or MLRS, which evaluates the BSA/AML and OFAC sanctions risks associated with bank products and serves as an important tool for the OCC’s BSA/AML/OFAC supervision program.

MLRS is currently applied to community banks, but the OCC is considering expanding the program to all banks supervised by the OCC, including large banks and federal thrifts. When that was initially suggested in April 2013, ABA raised serious questions about whether OCC had justified the costs associated with such a step.

The OCC is collecting information on burden estimates and invites comments on whether the expanded information collection is necessary; the accuracy of the agency’s estimate of the burden; ways to enhance the quality of the information collected; ways to minimize the burden of the information collection; and, costs of operation to provide information. Comments are due by March 4. For more information, contact ABA’s Rob Rowe.