The Clearing House (TCH) submitted a comment letter responding to the OCC’s second notice on its proposed expansion of the BSA Money Laundering Risk Assessment (MLR System) to large and midsize institutions under its supervision. Currently, the MLR System only applies to community banks. In the letter, TCH argues that: (i) the expansion of the MLR System’s “one-size-fits-all” information collection requirement is unlikely to benefit, and could actually undermine, public and private sector efforts to detect and combat money laundering and terrorist financing and is unnecessary, as large and midsize institutions already have full-time, embedded on-site examiners; (ii) the notice significantly underestimates both the standalone and cumulative burden that will be imposed on large and midsize financial institutions if the MLR System is expanded; and (iii) if the OCC does proceed with expanding the MLR System, a minimum implementation period of 24 months is necessary for large and midsize banks to comply with this reporting requirement.
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