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<p>WASHINGTON-While expressing their overall support in the war against terrorism and the role of money laundering in that, CUNA and NAFCU raised similar concerns in their respective comment letters regarding information sharing regs coming from the Financial Crimes Enforcement Network (FinCEN). Both groups expressed concern regarding the proposed definition of a “financial institution” and the time demands on financial institutions to fulfill compliance requirements. NAFCU said that additional guidance was needed from the agency on what was a reasonable effort to determine whether a named individual, entity, or organization was involved in a transaction. Additionally, NAFCU wrote that the institution’s size and technological capabilities should be a consideration in determining reasonableness. CUNA additionally wrote of their concern over the definition of `transaction’ in the regulation. “CUNA believes that addressing these concerns should help ease the burden and uncertainty for financial institutions without jeopardizing the aim of improved information sharing between financial institutions and government law enforcement agencies, as well as among financial institutions themselves,” CUNA Vice President of Communications and Media Outreach Pat Keefe said.</p>

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