WASHINGTON—The regulatory burden for completing suspicious activity reports (SARs) is larger than the Financial Crimes Enforcement Network (FinCEN) estimates, according to America’s Credit Unions.
“We believe the burden estimate to complete a SAR of two hours is low, as members report the process taking closer to four hours per SAR,” wrote Luke Martone in a letter to the agency. “In addition, we support an increase in the SAR reporting threshold from $5,000 to $10,000.”
Given that SARs involve suspicious activity by definition, the appropriate thresholds should simply be driven by inflation to ensure the policy goal of the thresholds remain intact, Martone said.
Martone further told FinCEN the regulatory burden from the entire AML/CFT framework is heavy, and is “amplified” by the fact 45% of credit unions have fewer than 10 employees.
The full letter can be found here.
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