Supplemental Annual PRA Burden Sample Clauses

Supplemental Annual PRA Burden. In the future, FinCEN intends to add a supplemental annual PRA burden calculation that will include the estimated hourly burden and cost to comply with forward- and backward- looking reporting requirements as part of filing reports of certain transactions with designated FFAs. This estimate will include the burden associated with implementing a monitoring system to identify such transactions. During the period from 2019 to 2021, FFA regulations issued by FinCEN had a forward- and backward-looking reporting requirement. Specified financial institutions were required to report forward 90–180 days out from the effective date of the regulation (usually the date of issuance), and backward 14 months to five years prior to the effective date of the regulation. Specified financial institutions were required to file one report for certain backward-looking transactions, and a report every 30-days for certain forward- looking transactions. As a result, one FFA regulation could result in as many as 7 different reporting periods.22 The majority of financial institutions combined the reportable transactions for all FFAs listed in one regulation 23 into a single report for each reporting period, thereby reducing the overall number of reports the financial institution might have otherwise provided. As noted above, FinCEN assesses that the volume of reportable transactions per financial institution and FFA request, over a specified forward- and backward-looking period, along with the burden to implement a monitoring system for such transactions, would be the best indication of an annual hourly burden estimate in the future. FinCEN does not have the necessary information to provide a tentative estimate for these supplemental PRA hourly burdens and costs within the current notice. In addition, FinCEN does not have all the necessary information to precisely estimate the traditional annual PRA burden. For that reason, FinCEN is relying on estimates used in prior renewals of this OMB control number and the applicable regulations. FinCEN further recognizes that after receiving public comments as a result of this 18 See Table 1.
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