ICBA responded to the Financial Crimes Enforcement Network’s proposed renewal of existing Bank Secrecy Act information sharing requirements, specifically Section 314(a), which requires banks to review their records upon receiving a FinCEN request and report any accounts or transactions involving named individuals or entities within a specified timeframe. FinCEN estimates that the average time to process a request per subject is only three and a half minutes. ICBA said that the burden associated with 314(a) compliance is far greater and urged FinCEN to adopt a more realistic assessment that accounts for differences in institution size, technological infrastructure, and operational capacity.