Modernization Of BSA Is ‘Long Overdue,’ CUNA Tells House

WASHINGTON—Modernization of the Bank Secrecy Act (BSA) reporting thresholds is “long overdue,” CUNA told the House this week.

The trade association wrote in support of a bill that would take such steps. The legislation—the Financial Reporting Threshold Modernization Act— was introduced by Rep. Barry Loudermilk (R-GA).

“In 1970, few ordinary consumer financial transactions exceeded $10,000—the current (and original 1970- designed) trigger for financial institutions to file Currency Transaction Reports (CTRs),” CUNA President/CEO Jim Nussle wrote.

“Nearly half a century later, however, the retail sticker price of even the most basic automobile exceeds $10,000, meaning credit unions engaged in the business of providing cooperative credit vehicle loans to member-owners need to investigate and fulfill burdensome paperwork requirements to inform the government of what they already know to be not suspicious activity—diverting resources from the business of lending and also obscuring actual suspicious financial activity from law enforcement,” he added.

The Bill’s Specifics

Specifically, Loudermilk’s bill would increase:

  • The CTR threshold to $30,000, up from the current $10,000. CUNA also noted the $30,000 number is “significantly less than the near $70,000 the threshold would be if adjusted for real inflation”
  • The dollar amount thresholds for filing Suspicious Activity Reports (SARs) to $10,000 (up from $5,000) and to $3,000 (up from $2,000)
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