CBA Urges FinCEN to support Flexibility in Enforcement of CDD Rule

On Wednesday, May 9, 2018, CBA sent a letter to the Financial Crimes Enforcement Network (FinCEN) expressing full support of its efforts to crack down on illegal activities through its final Customer Due Diligence Rule (CDD rule).  CBA expressed appreciation for the implementation time banks were given to comply with the complex data collection rule, particularly following unexpected developments and delays created compliance challenges for covered financial institutions (e.g. FAQs issued in early April and no FFIEC emanation guidance).  CBA requested that any examination materials offer flexibility for regulators and banks as they work together while implementing the new CDD rule.