Latest comments for http://www.ababj.com , comment 0 to 3 out of 3 comments http://www.ababj.com Sun, 26 May 2013 04:05:13 +0100 FeedCreator 1.7.2 http://www.ababj.com/myblog/were-going-to-need-a-bigger-boat.html#pc_54 What I can't figure out is why a lot of the FinCEN guidance takes so long to come out. Take the latest FinCEN guidance (ruling) on treatment of deposits by armored cars for CTR purposes. The guidance was requested in March and June of 2008. The guidance was dated July 2, 2009 (more than a year later). And then it didn't even get published for more than a month after that (August 13, 2009). What takes so long? It's called a "ruling," but it also has no public notice of proposal or advance warning. - Nancy D-C Mon, 24 Aug 2009 08:25:51 +0100 http://www.ababj.com/myblog/were-going-to-need-a-bigger-boat.html#pc_53 Another terrific post from Mr. Byrne. John hits it right on the head relating to regulatory guidance. While guidance is important -- particularly with principle-based regulatory regimes like most of the U.S. anti-money laundering regime -- the fact that "rules" are promulgated without interagency vetting or the notice and public comment required by the APA is a disturbing trend. The only answer is to engage with the regulatory body that issued the guidance. John's blog continues to add value. Nice work!! - William J. Fox Sun, 23 Aug 2009 11:44:40 +0100 http://www.ababj.com/myblog/were-going-to-need-a-bigger-boat.html#pc_52 As with the first two, this edition is full of insights that resonate with those of us who deal daily with implementation and examination while trying to make practical sense of guidance and enforcement actions. And I especially love the musical references to some of the greatest underappreciated rock groups (the Faces in a previous post and Buffalo Springfield in this one). Keep up the good work. - Steve Ganis Sun, 23 Aug 2009 07:03:23 +0100