In a comment letter to the Financial Crime Enforcement Network on its proposed rulemaking on cross-border electronic transmittals of funds, NAFCU asked the agency to consider the regulatory burden, the amount of information it already receives and the security issues involved with reporting sensitive data.

FinCEN's proposal includes two new requirements: Depository institutions would have to report all CBETFs and also file an annual report listing the taxpayer identification number for each accountholder who transmitted or received a CBETF that year.

Although the proposal is unlikely to create a significant regulatory burden for credit unions, NAFCU said, "it does add to the quite onerous regulatory burden associated with the other requirements of the Bank Secrecy ACT (BSA). Accordingly, NAFCU requests the Board simply consider all of those burdens together as it moves forward and makes a determination regarding the utility of requiring this new information."

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Regulatory & Compliance