Bank Policy Institute and The Clearing House

Summary: The Bank Policy Institute and The Clearing House Association support the proposed rule's shift toward a risk-based AML/CFT framework but argue that key principles from the preamble must be codified into the formal regulatory text. They request specific language to protect banks from "second-guessing" by regulators, clarify the distinction between "establishment" and "maintenance" failures, and provide clear definitions for terms like "reasonably designed" and "significant and systemic."