In a comment letter to the Financial Crimes Enforcement Network today, ABA urged FinCEN to conduct a “thorough and reflective analysis of the regulations that apply to both foreign correspondent accounts and private banking accounts,” noting that such a review is “needed and overdue.”
ABA’s comments came in response to a FinCEN proposal to renew without change its Paperwork Reduction Act methodology and estimate of the hourly burden and cost estimate associated with the information collection required for these types of accounts. While no changes will be made to the methodology at this time, FinCEN signaled that it will conduct a more thorough evaluation in the near future—a move supported by ABA.
The association pointed out that the current burden assessment methodology “barely scratches the surface of the time and effort associated with these account relationships,” and urged FinCEN to consider additional factors involved with opening the accounts, risk-rating customers and monitoring customer activity.
