The Clearing House Association and the Bank Policy Institute jointly responded to the FDIC’s request for feedback on a proposed Survey of the Costs of AML/CFT Compliance. The Association had previously responded to a prior request on the same proposed survey. The Associations expressed support for the survey’s goal of reducing compliance burdens and suggested several refinements to improve its accuracy and utility. Among other things, the Associations recommended expanding the survey beyond one year (2024) to capture multi-year variability, coordinating with other federal agencies to do similar surveys for consistency, and ensuring confidentiality of responses to encourage candid participation. As in the earlier response, the Associations also provided detailed feedback on each of the proposed survey questions. To see the full response click here.