Comment from the Bank Policy Institute and The Clearing House

Summary: The Bank Policy Institute and The Clearing House Association support the proposed transition to a risk-based AML/CFT framework but argue that the rule's text should more explicitly incorporate the principles currently found only in the preamble. They request specific language to protect banks from "second-guessing" by regulators, clearer definitions for "reasonably designed" and "systemic" failures, and a longer implementation period to allow for coordinated guidance and training.