Independent Community Bankers of America
Independent Community Bankers of AmericaSupportAdvocacy
Summary: The Independent Community Bankers of America (ICBA) supports the proposed risk-based, effectiveness-oriented AML/CFT framework but emphasizes the need for tailoring to the operational realities of smaller community banks. They argue that the final rule must avoid imposing large-bank standards, preserve relationship-based risk management, and provide clear guardrails against examiner-driven expansion of requirements.
ICBA's Comment Letter