SIA Submits Comments to the New York State Banking Department on the Reporting of Suspicious Transactions

The Securities Industry Association (SIA)* provides comments to the New York State Banking Department on the Superintendent of Banks’ proposed new part 302 of the Superintendent’s Regulations. The proposal would make every organization licensed or registered under the Banking Law of New York, or any agent of the organization, that is also subject to existing or future federal Suspicious Activity Reporting (SAR) requirements subject to identical state-reporting requirements. SIA believes there is not a compelling need for enactment of new state law that requires financial institutions to submit to the Superintendent duplicate copies of SARs filed with the Financial Crimes Enforcement Network (FinCEN).

*SIFMA is the product of a merger between the Securities Industry Association (SIA) and The Bond Market Association (TBMA) in 2006.