Wisconsin Bankers Association
Wisconsin Bankers AssociationSupportTrade association
Summary: The Wisconsin Bankers Association (WBA) supports the proposed reforms to modernize Bank Secrecy Act (BSA) requirements, specifically praising the shift toward a risk-based framework over arbitrary checklists. They request specific clarifications on definitions for "established" programs and "prompt" updates, as well as the inclusion of preamble commitments in the final rule to ensure regulatory consistency.
Please find attached WBA's comments regarding OCC–2024–0005.