Comment from American Bankers Association (ABA)

Summary: The American Bankers Association supports the proposed reforms to modernize Bank Secrecy Act (BSA) compliance by allowing risk-based resource allocation and establishing a safe harbor for compliant programs. They argue that while the proposals are a positive step toward reducing duplicative paperwork, the final rules should include specific language to protect banks from regulatory "second-guessing" of reasonable risk assessments and provide a longer implementation period following examiner training.