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The Independent Community Bankers of America appreciates the opportunity to respond to the Financial Crimes Enforcement Network’s decision to pursue a revised approach to the beneficial ownership information report that will be used to collect beneficial ownership information (“BOI”) reported to FinCEN pursuant to Section 6403 of the Corporate Transparency Act (“CTA”), enacted into law as part of the Anti-Money Laundering Act of 2020, enacted into law as part of the National Defense Authorization Act for Fiscal Year 2021.