The American Bankers Association (ABA) appreciates the opportunity to provide a Statement for the Record for this hearing, Oversight of the Financial Crimes Enforcement Network (FinCEN) and the Office of Terrorism and Financial Intelligence (TFI). The ABA is the voice of the nation’s $23.4 trillion banking industry, which is composed of small, regional and large banks that together employ more than 2.1 million people, safeguard $18.6 trillion in deposits and extend $12.3 trillion in loans.
The Committee plays a critical role in overseeing the TFI and FinCEN, and in particular the Treasury’s ongoing implementation of the Corporate Transparency Act (CTA). We appreciate the efforts of the Committee and FinCEN to address many of the concerns expressed by banks regarding the Notice of Proposed Rulemaking (NPRM) for FinCEN’s “Beneficial Ownership Information Access and Safeguard, and Use of FinCEN Identifiers for Entities (“access rule”). Although implementation of the novel beneficial ownership regulatory regime continues to pose significant challenges, the final access rule published in December 2023 substantially improves the original proposal by incorporating several ABA recommendations to address bank concerns.
Download to read the full text.
