Comment from Michigan Credit Union League
Michigan Credit Union LeagueSupportAdvocacy
Summary: The Michigan Credit Union League is commenting on behalf of its members, expressing general support for the proposed AML/CFT program framework while advocating for specific clarifications. They request clearer distinctions between mandatory requirements and supervisory guidance, more precise definitions for "significant failures," and a risk-based approach that avoids overly prescriptive "one-size-fits-all" requirements for smaller institutions.
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