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.