WASHINGTON--The Financial Crimes Enforcement Network (FinCEN) should use its existing statutory and regulatory authority to update Currency Transactions Report (CTR) and Suspicious Activity Report (SAR) thresholds. A letter sent to FinCEN Thursday from America’s Credit Unions details why the updates are needed, based on direct feedback from credit unions.
Modernizing these thresholds would “represent a targeted, commonsense regulatory reform that reduces burden on reporting entities, including credit unions, while maintaining the integrity of the Bank Secrecy Act framework,” wrote Luke Martone, America’s Credit Union regulatory advocacy senior counsel.
America’s Credit Unions worked closely with member credit unions—particularly the Small Credit Union Advocacy Advisory Panel—to provide data from institutions complying with the current, outdated thresholds, the trade group said.
ACU said FinCEN should:
- Raise the CTR reporting threshold to at least $30,000 and index for inflation going forward. The current $10,000 threshold has been unchanged since 1972
- Raise the SAR threshold to at least $10,000, as the current $5,000 threshold has not been updated since 1992
Martone added that the current statute gives the Treasury secretary “broad discretion to establish and adjust” the thresholds, and that doing so would align with the Administration’s current efforts to reduce unnecessary regulatory burdens. Relief would be especially impactful for smaller credit unions, which often operate with limited staff and must divert a disproportionate share of resources to high volumes of routine filings, Martone added.