In the preamble to the CDD rules adopted by FinCEN in 2016, FinCEN noted that most covered financial institutions already had significant CDD programs in place, so it didn't think the new rules would cause undue burdens in terms of compliance. If, in fact, most of these institutions already had robust CDD programs in place, do you think the new Rules were actually necessary? What are the advantages of putting these rules in place as opposed to relying on a financial institution's own incentives, under previous regulations and accepted market practices, to investigate and report suspicious account activities? Should these rules be expanded? If so, in what way(s)?