February 14, 2023

VIA ELECTRONIC SUBMISSION
Policy Division
Financial Crimes Enforcement Network
P.O. Box 39
Vienna, VA 22183

Re: FinCEN Notice of Proposed Rulemaking on Beneficial Ownership Information Access and Safeguards, and Use of FinCEN Identifiers for Entities (Docket Number FINCEN-2021-0005, RIN 1506-AB49/AB59)

Dear Sir or Madam:

The Securities Industry and Financial Markets Association (“SIFMA”)1 appreciates the opportunity to submit comments to the Financial Crimes Enforcement Network (“FinCEN”) on the notice of proposed rulemaking (“NPRM” or “Proposed Rule”) regarding access to beneficial ownership information (“BOI”) that will be reported pursuant to Section 6403 of the Corporate Transparency Act (“CTA”).2

SIFMA strongly supports the CTA’s objectives to protect U.S. national security interests and the U.S. financial system and to better enable efforts to counter money laundering, terrorism financing and other illicit activity by making it more difficult for malign actors to conceal their ownership of corporations, limited liability companies, and other legal entities in the United States.

1 SIFMA is the leading trade association for broker-dealers, investment banks, and asset managers operating in the U.S. and global capital markets. On behalf of our industry’s nearly one million employees, we advocate for legislation, regulation, and business policy affecting retail and institutional investors, equity and fixed income markets, and related products and services. We serve as an industry coordinating body to promote fair and orderly markets, informed regulatory compliance, and efficient market operations and resiliency. We also provide a forum for industry policy and professional development. With offices in New York and Washington, D.C., SIFMA is the U.S. regional member of the Global Financial Markets Association (GFMA).

2 FinCEN, Beneficial Ownership Information Access and Safeguards, and Use of FinCEN Identifiers for Entities, 87 Fed. Reg. 77404 (Dec. 6, 2022), https://www.federalregister.gov/documents/2022/12/16/2022-27031/beneficial-ownership-information-access-and-safeguards-and-use-of-fincen-identifiers-for-entities.