Overview
Title
Agency Information Collection Activities: Information Collection Renewal; Comment Request; Minimum Security Devices and Procedures, Reports of Suspicious Activities, and Bank Secrecy Act Compliance Program
Agencies
ELI5 AI
The government is asking people for their ideas on how banks can be safer and better at reporting suspicious activities. They want to make sure that giving them this information is not too hard or confusing for anyone.
Summary AI
The Office of the Comptroller of the Currency (OCC) has announced a request for public comments on the renewal of an information collection titled "Minimum Security Devices and Procedures, Reports of Suspicious Activities, and Bank Secrecy Act Compliance Program." This is part of their ongoing efforts to reduce paperwork and ensure compliance with the Paperwork Reduction Act. The information collection involves security requirements for banks and savings associations, such as designating a security officer and reporting suspicious activities. Comments are due by April 21, 2025, and will be used to evaluate the necessity, burden, and methods of the data collection process.
Abstract
The OCC, as part of its continuing effort to reduce paperwork and respondent burden, invites comment on a continuing information collection, as required by the Paperwork Reduction Act of 1995 (PRA). In accordance with the requirements of the PRA, the OCC may not conduct or sponsor, and the respondent is not required to respond to, an information collection unless it displays a currently valid Office of Management and Budget (OMB) control number. The OCC is soliciting comment concerning the renewal of its information collection titled, "Minimum Security Devices and Procedures, Reports of Suspicious Activities, and Bank Secrecy Act Compliance Program."
Keywords AI
Sources
AnalysisAI
The document from the Federal Register is a notice from the Office of the Comptroller of the Currency (OCC) inviting public comments on the renewal of an information collection related to the security procedures and compliance programs of banks and savings associations. This is part of ensuring these institutions effectively manage security risks and comply with the Bank Secrecy Act.
General Summary
The OCC is seeking comments on its proposal to renew a collection of information that involves the minimum security protocols these financial institutions must adopt. This includes designating a security officer, developing a written security program, and submitting reports on suspicious activities. The initiative is meant to enhance security and ensure legislative compliance. The public comment period is open until April 21, 2025.
Significant Issues and Concerns
One potential issue with the document is the lack of detailed explanation of how the estimated annual burden of about 1.27 million hours was calculated. This could be unclear to stakeholders who need transparency to assess the impact accurately. Moreover, the instructions for submitting comments electronically via the website www.reginfo.gov might be challenging for readers unfamiliar with the platform.
Additionally, while it is mentioned that all comments will be publicly disclosed, there is limited guidance provided on safeguarding sensitive information. This lack of directive might deter full participation or lead individuals to inadvertently include confidential data in their submissions.
Public Impact
For the general public, particularly those involved in the financial or regulatory community, the impact of this document is twofold. On one hand, it opens a channel for public input on the processes that govern essential security and compliance practices in financial institutions. On the other hand, the technical nature of the document might limit understanding to professionals within the industry, thereby potentially narrowing the audience who can meaningfully contribute feedback.
Impact on Stakeholders
Specific stakeholders, namely national banks and Federal savings associations, along with their designated security officers, will likely be directly impacted by the outcome of this information collection and any subsequent regulatory adjustments. These institutions must ensure they have the necessary protocols in place to report on suspicious activities and comply with the Bank Secrecy Act.
From a broader perspective, the ability of the OCC and other financial regulatory agencies to gather and respond to public input effectively can have significant implications for institutional transparency and oversight. While the document calls for feedback on ways to make the process less burdensome or more efficient, there is no mention of how the OCC plans to incorporate this feedback into actionable changes, which might concern stakeholders eager to see their contributions make a difference.
Overall, while the document aims to fulfill a critical regulatory function, its effectiveness will depend substantially on its accessibility and the ability to engage a diverse set of stakeholders in the discussion.
Issues
• The document lacks specific details on how the estimated total annual burden of 1,266,791 hours was calculated, which could be unclear to stakeholders.
• The instructions for submitting comments via www.reginfo.gov could be challenging for individuals unfamiliar with the platform, potentially hindering public participation.
• While the document provides mechanisms for submitting comments, it does not mention any feedback or support mechanism if a commenter encounters issues during submission.
• The document uses technical jargon, such as 'ICR Reference Number' and references to specific CFR codes, which may not be easily understood by a general audience.
• There is no mention of how the OCC plans to address or integrate the public comments received, which might concern stakeholders interested in the impact of their input.
• The document states that all comments will be made public and warns against including confidential information, but it does not provide clear guidance on how to protect sensitive data while still contributing effectively.