Comment from Wisconsin Bankers Association (WBA)
Wisconsin Bankers AssociationSupportTrade association
Summary: The Wisconsin Bankers Association (WBA) supports the proposed reforms to modernize Bank Secrecy Act (BSA) requirements, specifically praising the shift toward a risk-based resource allocation framework. They request specific clarifications on definitions, the codification of preamble commitments into final rules, and a 12-month implementation period to ensure smooth transition for member banks.
Please find attached WBA's comments regarding FINCEN–2026–0034.