Comment from Cooperative Credit Union Association
Cooperative Credit Union AssociationSupportAdvocacy
Summary: The Cooperative Credit Union Association, Inc., a state trade association representing approximately 200 credit unions, supports the proposed rule to reform AML/CFT requirements and reduce compliance burdens. They advocate for specific clarifications regarding "significant or systemic failures," the use of singular terminology for risk assessment processes, and mandatory consultation between FinCEN and the NCUA to ensure regulatory consistency.
See attached file(s)