ABA has issued a summary and analysis of the OCC’s proposed Paperwork Reduction Act request for re-approval of the Money Laundering Risk Assessment and expansion of the MLR to all OCC-supervised banks. Community national banks have been subject to the form for a number of years, but this would apply the data collection more broadly.
ABA in March strongly objected to the PRA request and the use of the PRA process rather than initiating a rulemaking. Despite ABA’s comments, the OCC submitted its PRA request to the Office of Management and Budget. The association is currently in the process of collecting feedback on how this action would affect midsize and large institutions. Comments are due by Sept. 7.
Read ABA's staff analysis.
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