On July 27, BPI submitted a comment letter to the Financial Crimes Enforcement Network (FinCEN) in response to the agency’s proposal to renew, without change, currently approved suspicious activity (SAR) information collection requirements and update an attending burden assessment, under the Paperwork Reduction Act (PRA). While BPI appreciates FinCEN’s efforts to enhance its SAR burden assessment, the letter stated that the proposal “still does not address the full range of activities engaged in by institutions in connection with satisfying SAR requirements.” Furthermore, the revised burden estimate is dramatically lower than financial institutions’ experience.
In the letter, BPI suggests that the agency should revise its burden assessment to include the full scope of resources devoted to SAR compliance and makes recommendations to enhance the utility of the SAR framework for law enforcement and national security efforts.
