CUNA Comment Letter

CUNA Comments on Transfer and Reorganization
of Bank Secrecy Act Regulations

March 9, 2009

Financial Crimes Enforcement Network
Department of Treasury
PO Box 39
Vienna, Virginia 22183

RE: FR Doc. E8-25550 Transfer and Reorganization of Bank Secrecy Act Regulations

To Whom It May Concern:

The Credit Union National Association (CUNA) appreciates the opportunity to comment on the Financial Crimes Enforcement Network's (FinCEN's) notice of proposed rulemaking and request for comments on the transfer and reorganization of the Bank Secrecy Act (BSA) regulations. By way of background, CUNA is the largest credit union trade organization in this country, representing approximately 90 percent of our nation's 8,200 state and federal credit unions, which serve more than 90 million members.

FinCEN proposes to move the Bank Secrecy Act regulations to a new chapter (Chapter X) and organize the regulations within Chapter X by financial industry to make it easier for institutions to find the appropriate regulatory requirements.

As outlined in the proposed rule, Chapter X will be organized in a manner that specifies the regulatory obligations applicable to particular industry sectors. Chapter X will feature consistent numbering and section divisions intended to make the regulatory requirements more accessible. FinCEN also proposes to add a standard definition for the Bank Secrecy Act (and the acronym "BSA") under the "General Definition" section of Chapter X. The current regulations do not contain a definition for the Bank Secrecy Act or the acronym "BSA." Finally, the rule proposes to make minor technical changes to the BSA regulations such as updating mailing addresses and points of contact. CUNA supports FinCEN's efforts to create more user-friendly BSA regulations and agrees that these proposed changes will facilitate use of the regulations. We commend FinCEN for taking these steps to aid financial institutions in meeting their BSA compliance responsibilities.

Thank you for the opportunity to express our views on the transfer and reorganization of the BSA regulations. If you have questions about our letter, please do not hesitate to give Senior Vice President and Deputy General Counsel Mary Dunn or me a call at 202-508-6739.

Sincerely,

Nichole Seabron
Federal Compliance Counsel