Teachers Insurance and Annuity Association of America
TIAASupportBusiness
Summary: TIAA, a financial services organization, expresses strong support for the proposal's goal of creating a risk-based AML/CFT framework. They argue for specific refinements to the rule, including the ability to exclude low-risk transactions from monitoring, risk-based employee training, the use of AI technology, and an increase in the SAR reporting threshold.
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. OCC–2024–0005.