BPI and the Clearing House Association Respond to FDIC’s Survey of the Costs of AML/CFT Compliance

Dear Mr. Meiers:

The Bank Policy Institute^[1] and The Clearing House Association^[2] (collectively, the "Associations") appreciate the opportunity to provide comments in response to the Federal Deposit Insurance Corporation's (FDIC's) request for information on a proposed information collection, a Survey of the Costs of Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) Compliance.^[3] The Associations strongly support the goals of the Bank Secrecy Act (BSA) and the continued evolution of the U.S. regulatory framework to ensure that financial institutions can effectively mitigate illicit finance risks while enabling responsible innovation. We also support the FDIC's stated aims for the draft survey to support rulemakings and guidance to "reduce compliance burden without compromising the effectiveness of current AML/CFT frameworks."

The draft survey reflects thoughtful consideration of the BSA compliance burdens facing financial institutions. In addition to comments on specific survey questions, we offer several general recommendations to better scope the survey and enhance the usefulness of the information collected.

• The survey seeks information about only one year, 2024. Because AML/CFT compliance costs are highly variable across years, depending on annual budgets and varying needs, a multi-year or comparative approach could produce a more accurate representation of ongoing compliance obligations.
• The Associations recommend that the FDIC coordinate with the other federal banking agencies and FinCEN, as appropriate, to ensure that any surveys they may issue to their supervised institutions closely track the proposed FDIC survey to ensure comparability of responses across institution types.

• The survey states that responses will be voluntary and "will not be used for supervisory purposes." It does not address whether responses will be protected from Freedom of Information Act (FOIA) requests or treated as Confidential Supervisory Information (CSI). The Associations request explicit assurances that responses will be treated as CSI and exempted from FOIA requests in order to promote candor and accuracy in survey results. We also recommend that responses be kept anonymized.

Please see our comments on each of the draft survey questions below..

To read the full comment letter, please click here, or click on the download button below.

[1] The Bank Policy Institute is a nonpartisan public policy, research and advocacy group that represents universal banks, regional banks, and the major foreign banks doing business in the United States. The Institute produces academic research and analysis on regulatory and monetary policy topics, analyzes and comments on proposed regulations, and represents the financial services industry with respect to cybersecurity, fraud, and other information security issues.

[2] The Clearing House Association L.L.C., the country's oldest banking trade association, is a nonpartisan organization that provides informed advocacy and thought leadership on critical payments-related issues. Its sister company, The Clearing House Payments Company L.L.C., owns and operates core payments system infrastructure in the U.S., clearing and settling more than $2 trillion each business day.

[3] Federal Deposit Insurance Corporation, Agency Information Collection Activities: Proposed New Information Collection; Survey of the Costs of AML/CFT Compliance; Comment Request, 90 Fed. Reg. 44,191 (September 12, 2025).