ALEXANDRIA, Va.— NAFCU said it generally supports the NCUA having express authority to exempt federally-insured credit unions from suspicious activity report (SAR) requirements, however it urges the agency to provide additional information and guidance.
That additional guidance, wrote Kaley Schafer Senior Regulatory Affairs Counsel, could include a letter to credit unions, separate from the final rule, regarding the application process, giving examples of innovative solutions that may be considered, and factors NCUA will consider.
“A supplemental guidance document that can be used in conjunction with the final rule will help assist FICUs seeking an exemption,” Schafer wrote.
NAFCU sent its comment in response to NCUA’s notice of proposed rulemaking regarding the Bank Secrecy Act (BSA).
“Since the passage of the Currency and Foreign Transactions Reporting Act, NAFCU members strive to ensure they provide accurate and timely SARs to assist law enforcement, the NCUA, and FinCEN,” wrote Schafer. “NAFCU has historically sought amendments to the current SAR reporting structure to reduce compliance burdens while ensuring credit unions still provide information with a high degree of usefulness. According to NAFCU’s 2020 Federal Reserve Meeting Survey, over 52% of respondents expect to increase the number of full-time equivalent staff members devoted to BSA/AML compliance. This represents a 20 percent increase from last year and will likely continue to grow, as compliance becomes more intricate. Providing the NCUA with the express authority to issue exemptions for SAR reporting to FICUs that develop innovative solutions that meet BSA requirements will certainly reduce regulatory burdens for those granted exemptive relief.”