Lastly, there are procedural deficiencies with this rulemaking process. FinCEN has provided for a comment period of only 15 days, over two holiday weekends — far shorter than the typical 60-day comment period.

Lastly, there are procedural deficiencies with this rulemaking process. FinCEN has provided for a comment period of only 15 days, over two holiday weekends — far shorter than the typical 60-day comment period.

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