Michigan Bankers Association • Arizona Bankers Association • Florida Bankers Association Current public policy challenges facing Comerica include compliance with and capital implications of new loan loss accounting standards (Current Expected Credit Loss or CECL model) and remaining engaged in the debate over such ongoing legislative issues as consumer privacy, cybersecurity, Bank Secrecy Act/Anti-Money Laundering (BSA/AML) reform and Community Reinvestment Act (CRA) modernization.