Comment from Financial Technology Association (FTA)
Financial Technology AssociationSupportAdvocacy
Summary: The Financial Technology Association (FTA) supports the proposed rule's shift toward a risk-based AML/CFT framework and its recognition of innovative technologies like AI. However, they request specific regulatory language to protect institutions from penalties on isolated errors when redeploying resources, a longer 24-month implementation timeline, and the extension of "significant or systemic" enforcement thresholds to non-bank financial institutions.
See attached file(s)