The Clearing House Association supports robust, effective anti-money laundering rules that work to protect the financial system and the public from the serious harm caused by money launderers and terrorists, and FinCEN’s effort to codify and clarify its rules regarding the customer due diligence responsibilities of financial institutions. Nevertheless, TCH believes FinCEN’s proposed definition of beneficial owner could be confusing, difficult to implement, and may not actually collect the information that law enforcement and regulators need.