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WASHINGTON-In a recent letter to the Financial Crime Enforcement Network, CUNA Assistant General Counsel Michelle Q. Profit communicated the organization’s support for allowing the expiration of an exception to the `Travel Rule’ in the Bank Secrecy Act. Allowing the CIF Exception-customer information files-to sunset means credit unions and other financial institutions would have to begin submitting the real name and address of the member making the funds transfer as of June 1. The exception granted a conditional exception allowing financial institutions to substitute coded information in a funds transmittal order. FinCEN implemented the CIF Exception and extended it twice already because financial institutions claimed that the reprogramming involved was very burdensome. Profit assured FinCEN Executive Associate Director of the Office of Regulatory Programs David Vogt that credit unions would be able to fully comply by the due date since many large credit unions do not make use of the exception. Profit’s letter indicated that FinCEN was looking to eliminate the exception “in light of congressional calls for financial transparency after the terrorist attacks and because of evidence of abuse of the exception.” She concluded, “It is reasonable to assume that expiration of this exception will make financial transactions more transparent and that this transparency will be helpful to law enforcement officials.”

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