Comment from TIAA
TIAASupportAdvocacy
Summary: TIAA, a retirement solutions and wealth management provider, expresses strong support for the proposed risk-based AML/CFT framework while requesting specific refinements. The organization argues for clearer language that allows institutions to exclude low-risk transactions from monitoring, implement role-appropriate training, and use innovative technologies like AI to improve compliance efficiency.
TIAA hereby submits the attached Cover Letter and Comment Letter in response to the joint Notice of Proposed Rulemaking titled "Anti-Money Laundering and Countering the Financing of Terrorism Programs," Docket ID. NCUA–2024–0033.