Comment deadline on FinCEN documents
FinCEN has published a Notice of Availability [80 FR 80308] of two related documents that are part of the proposed rulemaking on Customer Due Diligence Requirements for Financial Institutions that was published on August 4, 2014: a Regulatory Impact Assessment (RIA) and an Initial Regulatory Flexibility Analysis (IRFA). Comments on the RIA and/or IRFA will be accepted through January 25, 2016.
The comment period for the August 4, 2014, proposed rule closed on October 3, 2014. FinCEN received a total of 135 comments representing a wide range of views covering most aspects of the NPRM. A large number of commenters asserted that the NPRM lacked sufficient data to support its estimate of costs and substantially underestimated implementation and compliance-related costs. Based on comments and information received during further outreach to some financial institutions that provided comments on the proposal, FinCEN determined that the implementation and compliance-related costs may exceed $100 million annually, making this rulemaking an “economically significant regulatory action.” In such cases, agencies are required to conduct an RIA, and publish it for comment.