Comment from Wisconsin Credit Union League

Summary: The Wisconsin Credit Union League supports the proposed AML/CFT rules, praising the shift toward a risk-based, outcomes-oriented regulatory framework that reduces prescriptive burdens. However, the organization requests specific clarifications on "material" failures, the definition of "significant" enforcement actions, and the documentation of national AML/CFT priorities. They also urge the NCUA to address a specific issue regarding duplicative Currency Transaction Report (CTR) filings for armored car cash deliveries in Wisconsin.