Overview
Title
Agency Information Collection Activities: Information Collection Renewal; Submission for OMB Review; Minimum Security Devices and Procedures, Reports of Suspicious Activities, and Bank Secrecy Act Compliance Program
Agencies
ELI5 AI
The government wants people to share their thoughts on how banks keep things secure and report any strange activities to stop bad guys from doing bad things with money. They want to make sure this doesn't cause too much extra work for people, so they are asking for ideas on making it easier by the end of May 2025.
Summary AI
The Office of the Comptroller of the Currency (OCC) is requesting public comments on renewing their information collection related to security devices, suspicious activity reports, and compliance with the Bank Secrecy Act. This initiative is part of their ongoing efforts to reduce paperwork and respondent burden under the Paperwork Reduction Act of 1995. The public has until May 29, 2025, to submit their comments by various methods, including email and postal mail. The OCC aims to ensure that businesses comply with security procedures and suspicious transaction reporting, which helps in preventing and detecting financial crimes.
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." The OCC also is giving notice that it has sent the collection to OMB for review.
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Sources
AnalysisAI
The document from the Office of the Comptroller of the Currency (OCC) seeks public input on their ongoing information collection efforts concerning security measures, suspicious financial activities, and adherence to the Bank Secrecy Act. This request is part of the OCC's efforts to streamline processes and lessen the burden on paperwork for businesses and other stakeholders, as required by the Paperwork Reduction Act of 1995. Comments from the public are invited until May 29, 2025, and can be submitted through various means such as email or postal mail.
General Summary
The OCC is renewing its focus on collecting information related to security devices, procedures, and reports of suspicious activities at national banks and federal savings associations. This also includes ensuring compliance with the Bank Secrecy Act, an important regulation that aims to prevent and identify crimes involving financial institutions. The call for comments reflects the agency's intent to gather constructive feedback about the efficacy of these processes and whether they are appropriately balanced in terms of their burden and utility.
Significant Issues and Concerns
A few concerns arise from the document's presentation and content:
Complex Language and Terminology: The document uses technical language and references to regulatory codes (e.g., "12 CFR 21.2, 21.4") that may not be accessible to individuals without prior knowledge of federal regulations.
Burden Estimate: The stipulated burden of over 1.2 million hours for the completion of this collection may seem overwhelming. Without detailed context, it is difficult to gauge the reasonableness of such an estimate.
Multiplicity and Redundancy: The multiple suggested methods for submitting comments, including mail, fax, and email, might introduce confusion. A streamlined approach could enhance clarity and participation.
Lack of Clear Alternatives: While the document mentions reducing paperwork, it does not specify ways to achieve this goal or present simplified alternatives, potentially leaving stakeholders uncertain about possible improvements.
Impact on the Public
Broadly, this document aims to ensure that financial institutions maintain robust and effective security programs and are diligent in reporting illicit activities. For the general public, this can translate into an enhanced financial infrastructure where fraudulent and criminal activities are promptly addressed, thereby safeguarding customer assets and information.
Impact on Specific Stakeholders
Businesses and financial institutions are the most directly affected groups. They are required to adhere to the protocols set forth. For these entities, the notice signals a need to review and potentially adjust their compliance and reporting mechanisms to align with federal expectations. While this ensures better security and oversight, it does also mean sustaining significant administrative work.
Overall, while the OCC's efforts aim towards a safer financial environment, there is a clear need to address the document's complexity and improve public comprehension and involvement. More tangible examples and simplified processes would not only foster a broader understanding but also promote more meaningful feedback from stakeholders.
Issues
• The document does not specify any particular spending actions, thus it is challenging to identify wasteful spending or favoritism towards organizations or individuals.
• The language used in the document might be considered overly complex for individuals not familiar with legal or regulatory terminology, potentially making it difficult for the general public to understand.
• The document assumes a high level of familiarity with federal regulations and terms such as '12 CFR 21.2, 21.4, 168.2, and 168.4' and 'OMB control number 1557-0180,' which may not be easily understood by all readers.
• The burden estimate of 1,266,791 hours for the information collection might appear excessive without further context or breakdown, making it difficult to comprehend its justification fully.
• There might be some redundancy or confusion in specifying multiple submission methods for comments, which could be streamlined for clarity.
• No specific alternatives or simplified processes are clearly outlined for reducing the paperwork burden mentioned in the intent of the Paperwork Reduction Act.
• There is a lack of specific examples of how 'automated collection techniques or other forms of information technology' might minimize respondent burdens, which would enhance clarity and utility.