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Washington, D.C. — Two comment letters filed yesterday by the Bank Policy Institute and The Clearing House Association highlight opportunities to strengthen the nation’s anti-money laundering (AML) framework, including support for a recent regulatory proposal to make bank AML programs more risk-based and recommendations to address meaningful gaps in AML oversight of digital asset markets. …
Ladies and Gentlemen: The Bank Policy Institute,[1] The Clearing House Association L.L.C.,[2] and the Consumer Bankers Association[3] submit this letter in response to the notice of proposed rulemaking (“NPR”) issued by the Federal Deposit Insurance Corporation (“FDIC”) regarding GENIUS Act Requirements and Standards for FDIC-Supervised Permitted Payment Stablecoin Issuers and Insured Depository Institutions.[4] We appreciate …
Dear Mr. McDonough, The Clearing House Association[1] and the Bank Policy Institute[2] (“Associations”) appreciate the opportunity to respond to the proposed rule and request for comment (“Proposal”) on amendments to subpart C of Regulation J (governing the FedNow® Service) issued by the Board of Governors of the Federal Reserve System (“Board”).[3] The Associations support the objectives …
Ladies and Gentlemen: The Bank Policy Institute[1] and The Clearing House Association[2] are writing to comment on the notice of proposed rulemaking issued by the Financial Crimes Enforcement Network and the concurrent notice of proposed rulemaking (collectively, the “NPRM”) issued by the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation and …
BITS
BITS is the technology policy division of the Bank Policy Institute. BITS provides an executive level forum to discuss and promote current and emerging technology, foster innovation, reduce fraud and improve cybersecurity and risk management practices for the nation’s financial sector.
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The research department conducts long- and short-term analysis on issues primarily related to bank regulation and supervision with the objective of encouraging welfare-enhancing regulatory change. Our economists conduct academic-level research intended for presentation at conferences and publication in peer-reviewed journals.
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