The Clearing House (TCH) submitted a comment letter to the OCC on its proposed extension of its Bank Secrecy Act/Money Laundering Risk Assessment reporting requirement, also known as the Money Laundering Risk (MLR) System, to large and midsize banks within its jurisdiction. In the letter, TCH argued that: (i) there is no prudential or supervisory benefit to requiring the use of the MLR System for large or midsize banks that have full-time, embedded examiners on site; (ii) the proposal significantly underestimates the burden that will actually be imposed on financial institutions if the OCC were to extend the application of the MLR System; (iii) expanding the MLR System’s “one-size-fits all” information collection requirement to large and midsize banks is inconsistent with the OCC’s tailored supervisory approach to identifying BSA/AML risks and the uniform, risk-based framework for addressing BSA/AML risks established by the federal banking agencies and FinCEN; and (iv) at a minimum, should the OCC intend to expand the MLR System to large and midsize institutions, it should do so through a public notice and comment process that would explain the reasons for and attempt to justify the costs and burden of the expansion of the system.
TCH Files Comment Letter Arguing Against the OCC’s Proposed MLR System Expansion
