The Clearing House Association, along with five other trade associations, filed an amicus brief before the U.S. Supreme Court in Cummings v. Doughty. The brief asks the Court to clarify whether the safe harbor established by the Annunzio-Wylie Anti-Money Laundering Act provides the full immunity protection of the safe harbor provision from civil liability for claims arising out of the filing of a Suspicious Activity Report (SAR), or more qualified immunity from these claims. While most courts have held that the Act’s safe harbor provision grants a financial institution absolute immunity, the Louisiana court and some other courts decided to insert a good faith requirement to the safe harbor provision that would nullify the safe harbor. The brief argues that: (i) the Louisiana court decision conflicts with the plain language of the statute, (ii) the issue of whether the Act provides absolute immunity is unsettled and in need of review, and (iii) without absolute immunity banks will be hesitant to file SARs.