CUNA Offers FinCEN Improvements to BSA/AML Requirements

WASHINGTON – CUNA urged the Treasury’s Financial Crimes Enforcement Network (FinCEN) to ensure any regulatory changes it pursues relating to the collection of information filings be as minimally burdensome on credit unions as possible. CUNA’s letter was sent in response to proposed revisions to the collection of information filings by financial institutions required to file such reports under the Bank Secrecy Act (BSA), which includes credit unions.

“CUNA appreciates that FinCEN is not proposing any new regulatory requirements associated with Suspicious Activity Report (SAR) filing,” the letter reads. “However, it is important to note that any regulatory changes–even absent additional regulatory requirements–are likely to cause credit unions to expend time and resources to understand and make updates to reflect such changes.”

FinCEN is seeking comments in compliance with the Paperwork Reduction Act. The agency says the changes are technical in nature.

CUNA also encouraged FinCEN to:

  • Work toward greater regulatory and examination consistency among regulators, including the NCUA and state credit union regulators, in order to help with interpretations of BSA requirements and guidance and to minimize regulatory overlap;
  • Work with regulators to support meaningful legislative and regulatory changes to minimize the costs and problems financial institutions encounter in meeting BSA and anti-money laundering (AML) requirements. Increasing reporting thresholds would help reduce some of these compliance costs. This includes increasing the Currency Transaction Report (CTR) threshold to $20,000 from the $10,000 level established decades ago and at least doubling other key thresholds, such as the $3,000 trigger for reporting wire transfers and $5,000 threshold for filing a SAR; and
  • Eliminate duplicative reporting of information required to be entered into the SAR.

CUNA also suggested ease-of-use changes to the SAR and CTR form, including ways to make the filing process more efficient and accurate.

in Industry News