CUNA Regulatory Comment Call

February 11, 2009

FinCEN's Transfer and Reorganization of Bank Secrecy Act Regulations

EXECUTIVE SUMMARY

DESCRIPTION OF THE PROPOSED RULE

QUESTIONS REGARDING THE PROPOSED RULE

(FinCEN has specifically asked for comments on the first two questions below)

  1. Will the structure and numbering logic of the sections and parts within Chapter X make the FinCEN regulations more easily accessible?

    Yes ____ No _______

    If not, what structure should be used to organize the new chapter?
















  2. Whether organizing the new chapter based on an alphabetical scheme is clear, effective and of such value that FinCEN should reorganize the definitions at this time and each time a new one is added?

    Yes ____ No _______

    If not, what organization scheme would be more useful?
















  3. Do you think there are any additional technical changes that can be made to the current BSA regulations to make them more accessible and easier to use?
















Eric Richard • General Counsel • (202) 508-6742 • erichard@cuna.com
Mary Mitchell Dunn • SVP & Deputy General Counsel • (202) 508-6736 • mdunn@cuna.com
Jeffrey Bloch • Assistant General Counsel • (202) 508-6732 • jbloch@cuna.com
Luke Martone • Senior Regulatory Counsel • (202) 508-6743 • lmartone@cuna.com