Comment from Defense Credit Uniuon Council
Defense Credit Uniuon CouncilSupportAdvocacy
Summary: The Defense Credit Union Council (DCUC) supports the proposed transition toward a risk-based AML/CFT framework, noting that it allows credit unions to allocate resources more effectively based on their specific risk profiles. They urge the NCUA to ensure the final rule preserves flexibility for smaller institutions, provides consistent examiner training, and allows for a meaningful implementation period of 18-24 months.
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